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GoneCo, a foreign corporation incorporated in foreign country F, manufactures and sells speed skates. GoneCo owns a U.S. C corporation (USSub) that distributes only GoneCos

  1. GoneCo, a foreign corporation incorporated in foreign country F, manufactures and sells speed skates. GoneCo owns a U.S. C corporation ("USSub") that distributes only GoneCos skates. USSub uses the comparable profits method to show the arm's length nature of its transfer pricing. USSub can choose comparable companies from the following list of potentially comparable companies. All Berry Ratios are an average of gross profit over operating expense for the last 3 years.
    1. Brush Inc.: A distributor of dental care products. Brush has a contractor use Brushs proprietary manufacturing process to manufacture all the products Brush distributes. The contractor affixes the valuable Brush tradename to all the products it manufactures. Brush retains the right to all intellectual property. Berry Ratio = 1.10.
    2. Play Inc.: A sporting goods distributor. Berry Ratio = 1.05.
    3. Tent Inc.: A distributor of camping tents. Berry Ratio = 2.00.
    4. Cutter Inc.: A distributor of electronic knives. The companys sales are split 50-50 between the United States and the U.K.. Berry Ratio = 1.50.
    5. The Climb Inc.: A distributor of hiking gear. Berry Ratio = 1.15.
    6. Squeeze Inc.: A distributor of juicers. Berry Ratio = 1.20.
    7. Buddy Inc.: A distributor of pet toys. Berry Ratio = 1.00.

What is the arms length range? Why?

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