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. 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.
Special appendices provide a variety of "practice tools" designed to facilitate the understanding of the IRS' provisions and their translation into action, e.g., IRS forms, tables and charts of relevant cases, and comparisons of international transfer pricing rules within particular contexts.
Table of Contents (Summary)Chapter 1 IntroductionChapter 2 General Principles of Code Sec. 482Chapter 3 Methods for Transfers of Tangible PropertyChapter 4 Methods for Transfer of Intangible PropertyChapter 5 Intercompany ServicesChapter 6 Intercompany Loans and AdvancesChapter 7 PenaltiesChapter 8 The Code Sec. 1059A limitationChapter 9 Overall strategy for compliance and controversyChapter 10 Preparing transfer pricing documentationChapter 11 ExaminationChapter 12 Post-examination procedural alternativesChapter 13 Advance pricing agreementsChapter 14 The OECD approach to transfer pricingChapter 15 Customs valuation issuesChapter 16 State transfer pricinG