Practical guide to U.S. transfer pricing

3rd ed.
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Practical guide to U.S. transfer pricing
Robert T. Cole
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Last edited by ImportBot
January 17, 2023 | History

Practical guide to U.S. transfer pricing

3rd ed.
  • 0 Ratings
  • 0 Want to read
  • 0 Currently reading
  • 0 Have read

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Publish Date
Language
English
Pages
25

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Edition Availability
Cover of: Practical guide to U.S. transfer pricing
Practical guide to U.S. transfer pricing
2006, LexisNexis Matthew Bender
in English - 3rd ed.
Cover of: Practical guide to U.S. transfer pricing
Practical guide to U.S. transfer pricing
1999, Aspen
in English

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Book Details


Table of Contents

Overview of transfer pricing
Framework for U.S. transfer pricing analysis under treasury regulation Section 1.482-1
Determination of related person status
Finding and selecting comparables
Comparable uncontrolled price (CUP) method
Resale price method (RPM) and alternatives to traditional buy-sell
Cost plus method and location savings
Transfer pricing rules and methods for intangible property
Comparable profits method
Profit split methods
Unspecified methods
Functional analysis and choosing the best method
Cost sharing arrangements
Transfer pricing for services under the 1968 treasury regulations and the 2006 temporary treasury regulations
Determining arm's length interest and rent
Financial industry transfer pricing issues
Second-level effects of transfer pricing adjustments
Documented self-compliance to avoid penalties under IRC section 6662(e)
Advance pricing agreements (APAS)
IRC sections 6038A and 6038C : record-keeping, record production, and reporting for foreign-owned groups
Examination and appeals
Competent authority to avoid double or excessive taxation from transfer pricing adjustments
Transfer pricing litigation
Relationship of section 482 to other code sections
Transfer pricing effects of customs actions and customs effects of transfer pricing actions
State tax transfer pricing issues
International strategy for transfer pricing compliance : a checklist for multinationals.

Edition Notes

Includes bibliographical references and index.

Published in
Newark, NJ
Other Titles
Practical guide to United States transfer pricing

Classifications

Dewey Decimal Class
343.7305/268
Library of Congress
KF6465 .C573

The Physical Object

Pagination
v. (loose-leaf) ; 25 cm.
Number of pages
25

ID Numbers

Open Library
OL17923721M
ISBN 10
0820569496
LCCN
2006035669
OCLC/WorldCat
74492162

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History

Download catalog record: RDF / JSON
January 17, 2023 Edited by ImportBot import existing book
February 28, 2020 Edited by MARC Bot remove fake subjects
July 14, 2017 Edited by Mek adding subject: Internet Archive Wishlist
December 3, 2010 Edited by Open Library Bot Added subjects from MARC records.
December 8, 2009 Created by ImportBot add works page