Is There a Need to Do a 482 Analysis on a Disregarded Payment?

In many jurisdictions there are limitations based on the deductibility of royalties for example and so that there maybe hasn't been the need to be able to desire to do the full 482 analysis. So I think that can complicate things. The other example that you gave that resonated is you know if these are disregarded entities sitting underneath the US and you've got royalty payments coming from a disregndity, disregarded entity all that income kind of flows through probably hasn't been a whole lot of analysis. This could require taxpayers then to have to do a 482 analysis on a disregarded payment which again I think led you to more of just trying to focus on the jurisdiction as opposed to having