USAco, a domestic corporation, forms a Canadian subsidiary, CANco, to distribute USAco's widgets in Canada. USAco sells widgets to CANco for resale in Canada, provides CANco with USAco's unique distribution software, and provides the use of USAco's collections staff to collect receivables from delinquent accounts.
What are the intercompany transactions that USAco must price at arm's length?
What compliance techniques may USAco employ to minimize the risk of a transfer pricing penalty?