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Corporation Income Tax Return, including amended Forms 5471, Information Return With Respect to a Foreign Corporation, the Product sales from HP2 to FS1 based on the prices determined in the Country A transfer pricing examination instead of the actual prices charged by HP2.
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The amended returns that Taxpayer would be required to file to initiate the proposed Taxpayer-initiated adjustments for its Year 1 and Year 2 taxable years would decrease taxable income based on the Taxpayer-initiated allocations or other adjustments made with respect to the controlled transactions between.
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