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263A-2. Rev. Proc. 98 39 SECTION 1. PURPOSE. 01 This revenue procedure modifies which describes three alternative methods of accounting for package design costs 1 the capitalization method 2 the design-by-design capitalization and 60month amortization method and 3 the pool-of-cost capitalization and 48-month amortization method.
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Rev proc 98 39 refers to a revenue procedure issued by the Internal Revenue Service (IRS) that provides guidelines and instructions on how to obtain advance pricing agreements (APAs) related to transfer pricing.
Companies engaged in cross-border transactions with related entities are required to file rev proc 98 39 if they are seeking to establish APA agreements with the IRS regarding the pricing of those transactions.
To fill out rev proc 98 39, companies need to follow the guidelines provided in the revenue procedure. This includes submitting detailed information about the relevant transactions, pricing methodologies, and supporting documentation to the IRS for review and consideration.
The purpose of rev proc 98 39 is to establish a procedure for taxpayers to obtain certainty and avoid potential transfer pricing disputes with the IRS by entering into APAs. This helps promote compliance, reduce double taxation, and provide a predictable and consistent approach to transfer pricing.
Rev proc 98 39 requires companies to report detailed information about the cross-border transactions with related entities, including the nature of the transactions, pricing methodologies used, comparables analysis, and other relevant financial and economic data.
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