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Transfer Pricing Rules and Compliance Handbook

Transfer Pricing Rules and Compliance Handbook

Author: Marc M. Levey; Steven C. Wrappe; Kerwin Chung
Publisher: CCH U.S.
ISBN: 0808015532
Published In: January 2007
Format: Paperback , 228 pages
Jurisdiction: U.S. ? Disclaimer:
Countri(es) stated herein are used as reference only

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Contents
Author

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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.

1 Introduction
2 General Principles of Code Sec. 482
3 Methods for Transfers of Tangible Property
4 Methods for Transfers of Intangible Property
5 Intercompany Services
6 The Comparable Profits Method
7 Intercompany Leases, Loans and Advances
8 Encouraging Compliance: Penalties
9 Preparing Transfer Pricing Documentation
10 Overall Strategy for Compliance and Controversy
11 Advance Pricing Agreements
12 Impact of Transfer Pricing on Other Tax Issues
13 Impact of Transfer Pricing on Non-Tax Regulatory Issues

APPENDICES

Appendix 1 Glossary of Transfer Pricing Terms
Appendix 2 Comparison of Transfer Pricing Methods
Appendix 3 Transfer Pricing Documentation Example
Appendix 4 Transfer Pricing Dispute Procedural Flowchart
Appendix 5 Global Rules, Regulations and Guidelines
Appendix 6 Global Penalties on Transfer Pricing Assessments
Appendix 7 Global Documentation Requirements
Appendix 8 APA Program in Other Countries
Appendix 9 Other Transfer Pricing Publications

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 a partner in the Washington, D.C. Office of Mayer, Brown, Rowe & Maw LLP. 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, computer peripherals and components, education, industrial machinery, logistics, insurance, management consulting, and financial services. Kerwin has been recognized as one of the "World's Leading Transfer Pricing Advisors" by Euromoney Magazine.