USAco is the wholly-owned U.S. subsidiary of ASIAco, a Japanese parent corporation that manufactures automobiles and sells them to USAco for resale in the United States. ASIAco sells the automobiles to USAco for $20,000 and USAco resells the automobiles for $21,000. After a lengthy transfer pricing examination, the IRS proposes an adjustment, based on what it believes is the arm