Transfer Pricing: Rules, Compliance and Controversy (5th Edition) (Currently Unavailable)

Published: Feb 21, 2020

ISBN: 9780808053859
Product Number: 10015605-0003
Volumes: 1
Update Frequency: Annually
968 Pages

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Transfer pricing is one of the most significant tax issues for corporations having international operations. It attracts the scrutiny of tax authorities worldwide and continues to draw attention of more and more countries' tax legislatures. Because of the heavy impact of income allocations on the bottom line of a corporation's business, especially potentially forced ones, international tax and business professionals need to be very careful about their tax planning and compliance efforts in order to meet the established transfer pricing standards.

Transfer Pricing: Rules, Compliance and Controversy 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. Throughout the book, the 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.

The book's practical coverage and approach include:

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.

The thorough elaboration of the topics discussed, paired with clear and understandable writing, makes this new volume an excellent reference for both the experienced practitioner and the newcomer to the transfer pricing field.