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good away my name is Rob Ozzy and one of my continuing series on international tax issues today we talk about identifying intercompany transactions for transfer pricing purposes how do we get it we need intercompany transactions to have a transfer pricing issue so take your typical European business person theyre selling into the United States they come here to meet with a big customer they wake up real early in the morning because of the difference in the time zones they cant sleep well what do you do when you cant sleep in your estranged motel room you turn on the TV and why do you see on the TV youre going to see commercials for personal injury attorneys thats what I always sing when I turn on the TV at that time of the late night early morning and that scares the heck out of European business person so what do they do they form a distribution subsidiary they dont want to expose their assets in Europe to the personal injury attorneys here in the United States so what do they