30179

In any case of two or more organizations, trades, or businesses, whether or not incorporated, whether or not organized in Puerto Rico, and whether or not affiliated, owned or controlled directly or indirectly by the same interests, the Secretary is authorized to distribute, apportion, or allocate gross income and deductions, credits, or allowances between such organizations, trades, or businesses, if he/she determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or to clearly reflect the income of any of such organizations, trades, or businesses. The Secretary is also authorized to impute income by reason of interest, dividends, compensation or for any other concept or nature in transactions, trades or businesses when it is necessary to avoid tax evasion or to accurately reflect the income of any of such organizations, trades or businesses. History —Jan. 31, 2011, No. 1, § 1040.09, retroactive to Jan. 1, 2011.