How many years of data should be examined for the controlled transaction?
In order to obtain a complete understanding of the facts and circumstances surrounding the Controlled Transaction, it may be useful to examine data from both the year under examination and prior years. The examination of multiple-year data is typically done for 3 years inclusive of the year in which the transaction is undertaken. When using a 3-year period, at least 2 years of data should be available in order to accept the comparable company.