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

Author(s): Marc M. Levey, Steven C. Wrappe

Published: Jun 04, 2013
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ISBN: 9780808030928
Product Number: 10015605-0002
Volumes: 0
Update Frequency: As Needed
912 Pages

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. Transfer Pricing: Rules Compliance and Controversy (4th Edition) is now available in an eBook format which you can download to your computer instantly.

  • Table of Contents

Transfer Pricing: Rules, Compliance and Controversy (Fourth Edition)

Topics and Content


  • Chapter 1—Introduction
  • Chapter 2—General Principles of Code Sec. 482
    • Arm's length standard
    • Best method rule
    • Comparability
    • Arm's length range
    • Determination of true taxable income
    • Collateral Adjustments
    • Transfer pricing and non-recognition provisions
    • Blocked income
  • Chapter 3—Methods for Transfers of Tangible Property
    • Comparable uncontrolled price method (with cases applying this method)
    • Resale price method
    • Cost plus method
    • Cost-plus method
    • Comparable profit method
    • Profit split method
    • Unspecified methods
  • Chapter 4—Methods for Transfer of Intangible Property
    • Ownership of intangibles
    • Transfer of intangible property
    • Transfer pricing methods for intangibles
    • The commensurate with income standard and periodic adjustments
    • Cost sharing arrangements
    • Special rules for transfers to foreign corps
    • Significant IRS transfer pricing guidance
  • Chapter 5—Intercompany Services
  • Chapter 6—Intercompany Loans and Advances
  • Chapter 7—Penalties
    • History of Code Sec. 482 enforcement
    • U.S. transfer pricing penalties
    • Reporting penalties – Code Sec. 6038A
    • Code Sec. 982
    • Other penalties of general application
    • OECD transfer pricing 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
    • IRS pre-examination preparation
    • Taxpayer pre-examination preparation
    • Pre-examination conference
    • Overview of the examination process
    • The examination begins – gathering of information
    • Narrowing the issues – development of IRS positions
    • Settlement opportunities near the end of the examination process
  • Chapter 12—Post-examination procedural alternatives
  • Chapter 13—Advance pricing agreements
    • APAs and APA programs
    • Benefits sought by taxpayers
    • The APA negotiation process
    • Small business taxpayer APAs
    • Global APA programs
  • Chapter 14—The OECD approach to transfer pricing
  • Chapter 15—Customs valuation issues
  • Chapter 16—State transfer pricing
    • Practice Tools

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