Does Transfer Pricing Have a Loper Bright Problem?
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Does Transfer Pricing Have a Loper Bright Problem?
Thomas D. Bettge, Mark R. Martin, and Hans Gerling consider how the Supreme Court’s decision in Loper Bright may affect the application of section 482, the first sentence of which serves as the basis for the entire U.S. transfer pricing system but does not squarely address one of Loper Bright’s guardrails — the question of delegation.
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