Transfer Pricing: Rules, Compliance and Controversy (4th Edition)

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TPRCC-4117

Offers extensive yet clear guidance through the complex maze of U.S. transfer pricing rules. The book is authored by leading experts in the transfer pricing scene.

Offers extensive yet clear guidance through the complex maze of U.S. transfer pricing rules. The book is authored by leading experts in the transfer pricing scene. Authors cover all aspects of transfer pricing relevant to the practitioner, starting with general legal principles and apportionment methods, then moving on to more specific subjects such as transfers of tangible vs. intangible goods and the impact of e-commerce and U.S. customs on transfer pricing, and finally exploring highly practical matters like procedural strategies and post-examination procedures.

  • Comprehensive analysis of the U.S. rules, case law and guidance on transfer pricing for tangible goods, intangibles, and services
  • Complex cost-sharing planning principles, including buy-in*
  • Cutting edge e-commerce transfer pricing issues
  • U.S. penalty and documentation rules
  • Documentation with checklists, questionnaires and model report
  • U.S. penalty rules compared to those of other important countries
  • Overlap between transfer pricing and Customs valuation issues
  • Customs ruling based on an APA
  • In-depth, step-by-step analysis of the favored approach to transfer pricing controversy, including:
    • Developing a substantive/procedural strategy (with detailed flow-chart)
    • Preparing for examination
    • Identifying post-examination opportunities to resolve the dispute

Special appendices provide a variety of "practice tools" designed to facilitate the understanding of the IRS' provisions and their translation into action, e.g., IRS forms, tables and charts of relevant cases, and comparisons of international transfer pricing rules within particular contexts.

Table of Contents (Summary)
Chapter 1 Introduction
Chapter 2 General Principles of Code Sec. 482
Chapter 3 Methods for Transfers of Tangible Property
Chapter 4 Methods for Transfer of Intangible Property
Chapter 5 Intercompany Services
Chapter 6 Intercompany Loans and Advances
Chapter 7 Penalties
Chapter 8 The Code Sec. 1059A limitation
Chapter 9 Overall strategy for compliance and controversy
Chapter 10 Preparing transfer pricing documentation
Chapter 11 Examination
Chapter 12 Post-examination procedural alternatives
Chapter 13 Advance pricing agreements
Chapter 14 The OECD approach to transfer pricing
Chapter 15 Customs valuation issues
Chapter 16 State transfer pricinG

More Information
Updates N/A
Format Book
Allow Standing Orders No
ISBN 9780808030928