Transfer Pricing Rules and Compliance Handbook is a valuable overview and introduction for those involved in transfer pricing decisions in the United States, as well as foreign tax and business professionals with a need to deal with U.S. transfer pricing rules. It is the perfect introductory book for practitioners new to transfer pricing issues and business executives and financial managers who need to understand these important principles and rules that impact multinational business entities and operations. The book addresses the growing need for a working level of understanding of transfer pricing concepts. Over the last decade, transfer pricing decisions have become more important to multinational entities. The sheer magnitude of potential adjustments, combined with the ability to trigger cross-border tax disputes and the potential to have a material impact on financial reporting, ensures that transfer pricing will remain an area of continued corporate vigilance. Given the potential for transfer pricing decisions to globally impact tax, financial and operational results, it is important that financial and operational personnel at multinational entities who are making transfer pricing decisions possess the information they need. This book includes topics that will help them to make informed decisions. Such topics include: - the U.S. rules governing transfer pricing - how taxpayers can document transfer pricing determinations to avoid disputes - how to manage a transfer pricing examination - post-examination procedural alternatives to resolve transfer pricing disputes, and much more. This book also discusses the advance pricing agreement (APA) procedure, an approach whereby taxpayers prospectively agree with one or more tax authorities regarding their transfer pricing determinations. Finally, it covers the impact of transfer pricing on other tax issues, the impact of transfer pricing on non-tax regulatory issues including customs valuations, Section 404 of
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Marc M. Levey, partner with the New York office of Baker & McKenzie, is a nationally recognized expert in international taxation, particularly in structuring and defending transfer pricing strategies. Acknowledged by Euromoney magazine as one of the "Leading U.S. Tax Attorneys" and by the International Tax Review as one of the "World's Leading Transfer Pricing Advisors," his practice emphasizes transfer pricing and cross-border transactions, tax controversies and litigation, and general corporate and partnership taxation. Steven C. Wrappe, is the Director of APA and Competent Authority Services for Deloitte Tax in the Washington, DC National Tax Office. He has more than 25 years tax experience with 15 years of specialization in transfer pricing and Advance Pricing Agreements (APAs). He has had direct involvement in more than 100 APAs covering a cross-section of industries, transactions and methodologies, and he serves as global or North American transfer pricing adviser to a number of Fortune 500 companies. He is an internationally-recognized expert on transfer pricing and dispute resolution with numerous speeches and nearly 100 publications on transfer pricing topics to his credit. Recognized by Euromoney and the International Tax Review as a "Leading Transfer Pricing Advisor," he serves as Chair of the Transfer Pricing Committee of the ABA Section of Taxation. Wrappe is an adjunct professor at the Georgetown University Law Center (Transfer Pricing), and a regular guest lecturer in the LL.M. Program at New York University School of Law. Kerwin Chung, is a Firm Director in Deloitte Tax LLP's Washington National Tax Office with more than 10 years of transfer pricing experience. Kerwin specializes in Advance Pricing Agreements, competent authority, planning, examination and customs matters. He has represented U.S. and foreign-based multinationals in numerous industries, including: auto parts, pharmaceuticals, chemicals, electronics, construction equipment, comp
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First Sentence:
Transfer pricing refers to the pricing of transactions between related entities for goods, services, intangible property transfers, rents, and loans. Read the first page Key Phrases - Statistically Improbable Phrases (SIPs): (learn more)
prefiling submission, transfer pricing examination, transfer pricing report, tested party, transfer pricing documentation, transfer pricing analysis, uncontrolled transactions, profit level indicators, foreign competent authority, transfer pricing controls, intangible development costs, qualified cost sharing arrangement, best method rule, profit split method, competent authority process, foreign related party, cost sharing regulations, appropriate gross profit, global transfer pricing, comparable profits method, intercompany services, uncontrolled taxpayer, resale price method, combined operating profit, transfer pricing penalties Key Phrases - Capitalized Phrases (CAPs): (learn more)
Code Sec, United States, Tax Court, Selling Price, Letter Ruling, Daily Tax Rep, Eli Lilly, Footnote Continued, Internal Revenue Service, Tax Management Transfer Pricing Report New!
Books on Related Topics | Concordance | Text Stats Browse Sample Pages:
Front Cover | Table of Contents | First Pages | Index | Back Cover | Surprise Me!
Transfer pricing refers to the pricing of transactions between related entities for goods, services, intangible property transfers, rents, and loans. Read the first page Key Phrases - Statistically Improbable Phrases (SIPs): (learn more)
prefiling submission, transfer pricing examination, transfer pricing report, tested party, transfer pricing documentation, transfer pricing analysis, uncontrolled transactions, profit level indicators, foreign competent authority, transfer pricing controls, intangible development costs, qualified cost sharing arrangement, best method rule, profit split method, competent authority process, foreign related party, cost sharing regulations, appropriate gross profit, global transfer pricing, comparable profits method, intercompany services, uncontrolled taxpayer, resale price method, combined operating profit, transfer pricing penalties Key Phrases - Capitalized Phrases (CAPs): (learn more)
Code Sec, United States, Tax Court, Selling Price, Letter Ruling, Daily Tax Rep, Eli Lilly, Footnote Continued, Internal Revenue Service, Tax Management Transfer Pricing Report New!
Books on Related Topics | Concordance | Text Stats Browse Sample Pages:
Front Cover | Table of Contents | First Pages | Index | Back Cover | Surprise Me!
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