ComplianceLinks is a suite of services designed to provide Internal Revenue Code (IRC) § 482 economic auditing power to state clients. The modules of the ComplianceLinks section, as well as associated services Chainbridge provides are detailed below. Click on any of the module titles below to see how Chainbridge helps you enforce IRC Section 482.
What is Transfer Pricing?
Explaining transfer pricing can be a daunting prospect, but we’ve made it easy for you to learn what it’s all about here at chainbridge.com
If there is going to be a corporate income tax, it’s only fair that everyone pays it. Chainbridge helps states uncover corporations who haven’t paid theirs. Learn how here.
After a comprehensive analysis of your state’s corporate data, Chainbridge will produce an expert economist report including a complete functional analysis, and a relevant income adjustment for a given taxpayer. Chainbridge takes the complication out of 482 compliance with our revolutionary ComplianceLinks software, and our unparalleled transfer pricing expertise.
IRC §482 Regulations
Our approach in determining a final income adjustment for a particular taxpayer relies on section 482 of the U.S. Internal Revenue Code. It’s a method that’s been employed on the international level for decades, and our patented software along with our unrivaled experience in transfer pricing assures our clients that our analysis is both accurate and authoritative.
Should you choose to couple with Chainbridge, you’ll receive an extraordinary customer experience. We ensure that you’ll have our support every step of the way to the very end. Our analysts have served as experts in numerous court cases, and would be more than willing to offer the same services to your state.
Transfer Pricing Training
We have designed a state transfer pricing training program that will allow its graduates:
– to identify issues involving related party transactions that require further analysis,
– to suggest additional information needed from taxpayers related to the issues, and
– to recommend to supervisors the analytical support—legal, technical, and economic—needed for the agency to address the issues.
We are the only firm that has been fully dedicated to providing transfer pricing services exclusively to US state government tax agencies over the past decade. Our training program covers the following transfer pricing topics:
– What is transfer pricing?
– What are related party transactions?
– What are the various transfer pricing methods?
– IRS Advance Pricing and Mutual Agreement (APMA) program and IRC § 6662
– Transfer pricing abroad (briefly)
– Transfer pricing in the US states
– Taxpayer planning strategies
– Taxpayer strategies for dealing with state transfer pricing audits
– Relevant state statutes and regulations
– Applicable case law
– A state transfer pricing case study – a primer for state tax auditors
– The state transfer pricing case study portion of our training program covers the following topics:
– Identifying possible transfer pricing audit candidates using the Chainbridge preliminary analysis approach
– Determine whether or not controlled transactions exist
– What is the nature of the controlled transactions?
– Are intercompany price distortions occurring?
– Should a formal IRC § 482 audit be performed?
– Generate Information Document Request (IDR) “package”
– Review taxpayer response to the IDR package
– Generate state Economist’s Report
– Generate Notice of Proposed Assessment
– Post-audit support
We would be happy to discuss the details of our training program with you – please feel free to contact us.
Who We Are
Chainbridge’s exceptional team of consultants and software developers have been in the business of tax for more than half a century collectively. Learn more about the brains behind Chainbridge’s unprecedented tax software by clicking the icon above.
Chainbridge has been providing tax models, and transfer pricing insight to numerous state clients across the country. Navigate our experience map to find out which of your neighboring states has partnered with Chainbridge to establish an effective tax program.