Review the pricing of intercompany transactions to determine whether arms length pricing can be established to rebut the presumption of distortion stemming from substantial intercorporate transactions. Review the potential exposure associated with the disallowance of expenses attributable to subsidiary capital. Consider planning strategies to minimize the impact of an expense attribution adjustment. The potential tax savings in combined reporting are worth the effort of developing an action plan if the requirements can be met. The deadline for requests to file on a combined basis for 1992 is January 30, 1993.
Time is short.