Transfer Pricing: Rules, Compliance and Controversy

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9780808016564: Transfer Pricing: Rules, Compliance and Controversy

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. Practical Guide to Transfer Pricing Rules and Compliance 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 comparedto 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-exami

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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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Marc M. Levey, Steven C. Wrappe
Published by CCH, Inc. (2008)
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Marc M. Levey; Steven C. Wrappe
Published by CCH, Inc. (2008)
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