26 U.S. Code § 1059A - Limitation on taxpayer’s basis or inventory cost in property imported from related persons
(a) In general
If any property is imported into the United States in a transaction (directly or indirectly) between related persons (within the meaning of section 482), the amount of any costs—
(1) which are taken into account in computing the basis or inventory cost of such property by the purchaser, and
shall not, for purposes of computing such basis or inventory cost for purposes of this chapter, be greater than the amount of such costs taken into account in computing such customs value.
(b) Customs value; import
For purposes of this section—
(1) Customs value
The term “customs value” means the value taken into account for purposes of determining the amount of any customs duties or any other duties which may be imposed on the importation of any property.
Source(Added Pub. L. 99–514, title XII, § 1248(a),Oct. 22, 1986, 100 Stat. 2584.)