Epstein File EFTA00672561: Controlled (DS9)

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💨IMPACT LEVEL 1 — MEH

Epstein File EFTA00672561: Controlled (DS9)

General DocumentDate unavailableEFTA006725611 keyword hits

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This document discusses IRS Section 482 regulations regarding income and loss reallocation between entities under common control, and references principles that may be asserted by the NYC Department of Finance for expense reallocation among commonly owned or controlled entities. The excerpt addresses tax law principles applicable to related entity transactions.

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controlled

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Excerpt 1

In general, Section 482 of the Code allows the IRS to reallocate income and losses between entities that are **controlled** by the same interests in order

Excerpt 2

principles are more likely to be successfully asserted by the NYC Dept. of Finance if the asserted reallocation of expenses was between commonly owned or **controlled**