Build a transfer-pricing facts table for related-party dealings
Key facts
- Human involvement
- RedLawyer-led
- How AI is used
- Extract the related parties, the transactions, the intangibles and the amounts from the file into a facts table. Write no method, no adjustment and no paper that will go to the IRS.
- What the lawyer must review
- 26 U.S.C. § 482 lets the Secretary allocate gross income, deductions, credits or allowances among organisations, trades or businesses owned or controlled by the same interests when that is necessary to prevent evasion or to reflect income clearly. For a transfer or licence of intangible property, the income must be commensurate with the income attributable to the intangible, and the Secretary must require an aggregate valuation, or a valuation based on realistic alternatives, when that is the most reliable means. You choose the method and you write any advice or filing. OPR Issue 2026-19 applies Circular 230 § 10.37 to written advice that uses a generative tool: review it before it goes to the client.
- Written for / version
- United States versionUSCth
Who does what
| Role | What they do |
|---|---|
| Assistance | Supporting preparation only. Potential support includes extracting and organising information. Confirm the tool’s capability and permitted scope. The tool writes nothing into the document. Substantive advice, judgement and any restricted content remain with the responsible human. |
| Lawyer | Perform the substantive analysis and decisions. Independently check any permitted supporting work and approve the exact output for its intended use. |
Checklist
- Trace every relied-on figure to its source, confirm dates and assumptions, and independently recalculate totals or derived amounts.
- Check the current court or regulator requirements, prescribed form and attachments for the intended document and filing.
- Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
- Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.