Today, Treasury and the IRS issued temporary regulations clarifying the coordination of the transfer pricing rules with other provisions.  The preamble to the regulations states that Treasury and the IRS are concerned that “certain results reported by taxpayers reflect an asserted form or character of the parties’ arrangement that involves an incomplete assessment of relevant functions, resources, and risks and an inappropriately narrow analysis of the scope of the transfer pricing rules.”  The temporary regulations provide that arm’s length compensation must be consistent with, and must account for all of, the value provided between the parties in a controlled transaction, without regard to the form or character of the transaction.  The temporary regulations also expand the circumstances in which two or more separate transactions must be aggregated under the transfer pricing rules and other provisions.  The regulations apply to taxable years ending on or after September 14, 2015.