---
title: "Build a transfer-pricing facts table for related-party dealings"
url: "https://ailawframework.com/practice/taxation/build-a-transfer-pricing-facts-and-methods-table/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A26-T1-R9-US"
practice_area: "Taxation"
tier: "red"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Build a transfer-pricing facts table for related-party dealings

> 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.

Canonical page: https://ailawframework.com/practice/taxation/build-a-transfer-pricing-facts-and-methods-table/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Taxation](https://ailawframework.com/practice/taxation.md) |
| Human involvement | Red: Lawyer writes; AI may check, clarify or collect data |
| 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 | United States |
| Applies to | [Build a transfer-pricing facts and methods table](https://ailawframework.com/practice/taxation/build-a-transfer-pricing-facts-and-methods-table.md) |

## Checking plan

- What the AI does: 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.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- The Treasury regulations under § 482 are the working rules for methods. Open the regulation you rely on. Do not stop at the statute.
- Do not put intercompany agreements or return information into a public tool.

## Sources

- [26 U.S.C. § 482, Allocation of income and deductions among taxpayers](https://www.law.cornell.edu/uscode/text/26/482) (checked 2026-10-22)
- [IRS Office of Professional Responsibility, Issue 2026-19](https://www.irs.gov/pub/opr-taxpros/issue-number-2026-19-introductory-guidelines-for-responsible-ai-use-in-federal-tax-practice.pdf) (checked 2026-10-22)

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*