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

Name: Transfer Pricing: Rules Compliance and Controversy (5th Edition)
Brand: CCH U.S.
SKU: 9780808053859
Price: 2502.60 HKD
Availability: InStock
Author: Marc M. Levey; Steven C. Wrappe
ISBN: 9780808053859

Edited by Marc M. Levey · Steven C. Wrappe

CCH U.S. February 2020

Specifications

ISBN-13: 9780808053859
Publisher: CCH U.S.
Publication: February 2020
Format: Paperback , 1089 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.