- Indicate the intended tax treatment each of the 16 C.F.R. Part 801–803 fee.
- Enclose a copy of each Form 16 C.F.R. Part 803–Appendix filed or required
to be filed in the taxable year of issue. Include any supplemental information
included in Form 16 C.F.R. Part 803—Appendix. Include all information re-
quested by the FTC or the DOJ.
(j) NAICS Reporting. Specify the following information for each sixth digit, sev-
enth digit, or tenth digit NAICS classification under FTC Form C4 item 5 for the year
under review.
- Gross revenues
- Operating expenses
- Operating income
(k) U.S.-Connected Products or Services. Specify the following information for
each sixth digit, seventh digit, or tenth digit NAICS classification under FTC Form
C4 item 5 for the year under review.
- Gross revenues
- Operating expenses
- Operating income
Amounts provided in items 1 through 4 provide the IRS with comparative data
that may lead the international examiner to request subsequent Transfer Pricing In-
formation Document Requests.
Prior versions of portions of this analysis appeared in the May or June 2002 edi-
tion of Corporate Business Taxation Monthly(Panel Publishers), edited by Robert
Feinschreiber and Margaret Kent, and in Mergers and Acquisitions: The Monthly Tax
Journal(Panel Publishers), edited by Robert Feinschreiber and Margaret Kent. This
analysis was undertaken in part at the request of the Internal Revenue Service. A sig-
nificant portion of this analysis remains embargoed by the Internal Revenue Service.
29 • 40 TRANSFER PRICING FOR INTERCOMPANY TRANSACTIONS