TaxGuided
United States IRC sections

Statute section

IRC section 482

Allocation of income and deductions among taxpayers

Country

United States

Section

482

Updated

2026-05-20

Operative text

Section 482 authorizes the IRS to distribute, apportion, or allocate gross income, deductions, credits, and allowances between or among related parties to clearly reflect income or prevent tax evasion. The implementing regulations establish the transfer-pricing methodologies and arm's-length-principle framework.

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Primary sources

Important disclaimer

This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.