The Utah Tax Court recently issued its decision in Seeās Candies, Inc. v. Utah State Tax Commission, Case No. 140401556, holding that the āarmās-lengthā standard set forth in the federal treasury regulations relating to section 482 of the Internal Revenue Code (āIRCā) controls for purposes of guiding the Utah State Tax Commission (āCommissionā) in reallocating income pursuant to Utah Code section 59-7-113 (āSection 59-7-113ā), which is nearly identical to section 482 of the IRC.
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