Adjustments the Secretary may make to intercompany transactions that are found to lack economic substance or not to be at fair market value include the following:

1. (1) Disallowing deductions in whole or in part;
2. (2) Attributing income to related corporations;
3. (3) Disregarding transactions; and
4. (4) Reclassifying income as apportionable or allocable.

History Note: Authority G.S. 105-130.5A; 105-262.1;
Eff. January 31, 2013;
Pursuant to G.S. 150B-21.3A, rule is necessary without substantive public interest Eff. August 19, 2017.