Authors:

  • Stephen E. Shay

Excerpt

Formulary Apportionment in the U.S. International Income Tax System: Putting Lipstick on a Pig? Stephen Shay, February 2014, Paper. "An affiliated corporate group consists of two or more corporations linked by sufficient stock ownership to cause them to function as an economic unit instead of as independent economic actors. Thus, an affiliated corporate group engaged in international business is often referred to as a multinational enterprise (MNE), a term that we will use throughout this Article. When corporate members of an MNE engage in transactions among themselves, the prices they employ (transfer prices) will..."  Link