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Transfer Pricing

Transfer Pricing Rules, Compliance and Controversy (3rd Edition)

Name: Transfer Pricing
Brand: CCH U.S.
SKU: 9780808021667
Price: 1940.00 HKD
Availability: OutOfStock
Author: Marc M. Levey; Steven C. Wrappe
ISBN: 9780808021667

Edited by Marc M. Levey · Steven C. Wrappe

CCH U.S. August 2010

Specifications

ISBN-13: 9780808021667
Publisher: CCH U.S.
Publication: August 2010
Format: Paperback , 912 pages
Jurisdiction: U.S. ? Countri(es) for reference only

Details

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.

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

About the Author

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.

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