the filer derived dollar revenues of $1 million or more in the most recent year. The
acquired issuer either derived revenues of $1 million or more in the recent year or de-
rived revenues of $1 million or more in the most recent year attributable to the ac-
quired assets. The $10 million amount applies to joint ventures.
The material in italics explains the background for the request is for IRS use only.
The international examiner may opt to exclude this material in issuing the standard
transfer pricing information document request.
29.22 PROPOSED SECOND STANDARD TRANSFER PRICING INFORMATION
DOCUMENT REQUEST
(a) Classification. This information document request seeks information regarding
revenues, expenses, U.S.-connected products and services, and net income for lines
of commerce, determined under the North American Industry Classification Sys-
tem—United States, 1997, the 1997 NAICS Manual published by the Executive Of-
fice of the President, Office of Management and Budget.
(b) Consistency. All information sought pursuant to this information document re-
quest shall be prepared in conjunction with the information otherwise requested and
submitted pursuant to the Notification and Report Form for Certain Mergers and Ac-
quisitions, 16 C.F.R. Part 803—Appendix.
(c) Applicability. The information document request seeks detailed information re-
garding each acquisition of assets or voting stock that is $50 million or more, based
on the aggregate total of assets and voting stock to be held as a result of the acquisi-
tion. Information pertaining to acquisitions of less than $50 million, based on the ag-
gregate total of assets and voting stock to be held as a result of the acquisition, are
exempt.
(d) Information Requested. Information requested is to be determined under two
NAICS levels:
1.Unless otherwise specified, the information sought must be reflected at the six-
digit NAICS national industry code level.
2.Activities pertaining to manufacturing operations (as defined by NAICS Sec-
tions 31 through 33) must be submitted at the seven-digit NAICS product class
and at the ten-digit NAICS product code level.(e) U.S.-Connected Products or Services. U.S.-connected products or services
means products or services that are imported to or exported from the United States
by transfers by the taxpayer and any of its related parties. For this purpose, exports
are added to each other and are not subtracted. The definition of “U.S.-connected
products or services” is taken from the definition of that term as specified in Treasury
Regulation Section 1.6038A-3(c)(7)(i). The Second Transfer Pricing Information
Document Request terminology is somewhat broader than the comparable term in the
regulations. The Second Transfer Pricing Information Document Request refers to all
related parties, but Treasury Regulation Section 1.6038A-3(c)(7)(i) applies only to
“foreign” related parties.
29 • 38 TRANSFER PRICING FOR INTERCOMPANY TRANSACTIONS