Answered step by step
Verified Expert Solution
Question
1 Approved Answer
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
- 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.
- 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.
- Play Inc.: A sporting goods distributor. Berry Ratio = 1.05.
- Tent Inc.: A distributor of camping tents. Berry Ratio = 2.00.
- 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.
- The Climb Inc.: A distributor of hiking gear. Berry Ratio = 1.15.
- Squeeze Inc.: A distributor of juicers. Berry Ratio = 1.20.
- Buddy Inc.: A distributor of pet toys. Berry Ratio = 1.00.
What is the arms length range? Why?
Step by Step Solution
There are 3 Steps involved in it
Step: 1
Get Instant Access to Expert-Tailored Solutions
See step-by-step solutions with expert insights and AI powered tools for academic success
Step: 2
Step: 3
Ace Your Homework with AI
Get the answers you need in no time with our AI-driven, step-by-step assistance
Get Started