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rephrase this paragraph: Over the years, the IRS rules related to the distribution of income and deductions for Multinational Corporations (MNCs) have experienced substantial modifications.

rephrase this paragraph: Over the years, the IRS rules related to the distribution of income and deductions for Multinational Corporations (MNCs) have experienced substantial modifications. These changes aim to encourage equitable taxation and deter tax evasion. The evolution of these regulations can be traced back to the introduction of the concept of "arm's length" pricing by the Bureau of Internal Revenue (BIR) in 1928 (Kumar, U., 2022). This principle mandates that associated entities should set their transaction costs as though they were dealing with independent parties. In 1968, the IRS issued comprehensive regulations under Section 482 of the Internal Revenue Code, providing detailed guidance on the arm's length standard and introducing methods for determining arm's length pricing (FREEMAN LAW, n.d.)

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