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Practical Guide to U.S. Transfer Pricing

Author : Robert T. Cole
Publisher : Aspen Publishers
ISBN 13 :
Total Pages : 1302 pages
Book Rating : 4.0/5 ( download)

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Book Synopsis Practical Guide to U.S. Transfer Pricing by : Robert T. Cole

Download or read book Practical Guide to U.S. Transfer Pricing written by Robert T. Cole and published by Aspen Publishers. This book was released on 1999 with total page 1302 pages. Available in PDF, EPUB and Kindle. Book excerpt: Practical Guide to U.S. Transfer Pricing is a total approach to U.S. transfer pricing For The complex global marketplace. No book on the market today offers you a more thorough approach to transfer pricing rules that Practical Guide to U.S. Transfer Pricing. The tremendous increase in international trade among the nations of the world has made transfer pricing the most important international tax issues for governments. Thus, it is a major problem for major multinational corporations, which are subject to detriments from transfer pricing rules and adjustments, especially double taxation, penalties, And The cost of compliance. Packed with ready-to-use guidelines, detailed examples, and useful tips, Practical Guide to U.S. Transfer Pricing has been specifically designed to help you make today's transfer pricing rules work for your corporation. The book brings together For The first time, a wealth of features that will empower you to deal quickly and efficiently with all transfer pricing issues and problems. You will find: Unsurpassed coverage of U.S. transfer pricing substantive rules Incisive comparisons of the U.S. rules To The international accepted OECD Transfer Pricing Guidelines Information on both special and traditional procedures for transfer pricing cases Comprehensive explanations of all major transfer pricing methods, such as the Comparable Uncontrolled Price Method, Cost Plus Method, Comparable Profits Methods, and Profit Split Method Criteria for choosing the best transfer pricing method Ideas on how to cope with the U.S. rules in light of foreign requirements A checklist that multinationals can use in developing an international strategy for transfer pricing compliance A full description of the proposed method of global trading of financial products.

Framework for U.S. Transfer Pricing Analysis Under Treasury Regulation Section 1.482 and the OECD Guidelines Compared

Author : Robert Cole
Publisher :
ISBN 13 :
Total Pages : 0 pages
Book Rating : 4.:/5 (137 download)

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Book Synopsis Framework for U.S. Transfer Pricing Analysis Under Treasury Regulation Section 1.482 and the OECD Guidelines Compared by : Robert Cole

Download or read book Framework for U.S. Transfer Pricing Analysis Under Treasury Regulation Section 1.482 and the OECD Guidelines Compared written by Robert Cole and published by . This book was released on 2016 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This chapter from a Practical Guide to Transfer Pricing (Lexis) compares the U.S. Section 482 transfer pricing regulations to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations as revised in 2010. Section 482's purpose is to ensure that taxpayers subject to U.S. taxation "clearly reflect income" related to transactions with other organizations that are under common ownership or control with the taxpayer, and "to prevent the avoidance of taxes with respect to such transactions." The desired result is "tax parity" between the "controlled taxpayer" and an "uncontrolled taxpayer," and, thereby, to determine the "true taxable income" of the controlled taxpayer. Similarly, the 2010 Guidelines state that the arm's length standard which flows from recognizing the separate entity status of related entities in different jurisdictions has the dual objective of securing an appropriate tax base in each jurisdiction and avoiding double taxation. Since many U.S. trading partners follow the OECD Guidelines (and to a certain extent the United States also does) similarities and differences between the OECD Guidelines and the U.S. regulations are important.

Transfer Pricing Rules and Compliance Handbook

Author : Marc M. Levey
Publisher : CCH
ISBN 13 : 9780808015536
Total Pages : 232 pages
Book Rating : 4.0/5 (155 download)

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Book Synopsis Transfer Pricing Rules and Compliance Handbook by : Marc M. Levey

Download or read book Transfer Pricing Rules and Compliance Handbook written by Marc M. Levey and published by CCH. This book was released on 2006 with total page 232 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book gives an overview of the basic principles of transfer pricing and U.S. transfer pricing rules, and the impact of transfer pricing on other issues such as customs valuation, Section 404 of the Sarbanes-Oxley Act of 2002, and FASB Interpretation no. 48.

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022

Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264921915
Total Pages : 658 pages
Book Rating : 4.2/5 (649 download)

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Book Synopsis OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 by : OECD

Download or read book OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 written by OECD and published by OECD Publishing. This book was released on 2022-01-20 with total page 658 pages. Available in PDF, EPUB and Kindle. Book excerpt: In a global economy where multinational enterprises (MNEs) play a prominent role, governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation.

Transfer Pricing Methods

Author : Robert Feinschreiber
Publisher : John Wiley & Sons
ISBN 13 : 0471651230
Total Pages : 338 pages
Book Rating : 4.4/5 (716 download)

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Book Synopsis Transfer Pricing Methods by : Robert Feinschreiber

Download or read book Transfer Pricing Methods written by Robert Feinschreiber and published by John Wiley & Sons. This book was released on 2004-03-01 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: Advanced praise for Transfer Pricing Methods "Feinschreiber and a team of renowned executives have provided the definitive transfer-pricing guide to this challenging area. At a time when many companies are reviewing documents, policies, and procedures, it's wonderful to have a concise, clearly written reference focused on what may be the most critical corporate tax issue." -Charles R. Goulding, Managing Director, Tax Cooper Industries, Inc. "It is refreshing to find a treatise on transfer pricing that combines practical business considerations, economic theory, and a discussion of technical tax rules in a way that is meaningful not only for large corporate enterprises but also small and medium-sized businesses." -Vikram A. Gosain, JD, CPA, Director of Transfer Pricing General Electric Capital Corporation "This well-written book will be useful both to attorneys new to the practice area and to older hands. It includes very helpful discussions on valuation issues that will be particularly useful for in-house counsel and accountants." -Joseph C. Mandarino, Partner Troutman Sanders, LLP "Feinschreiber and his contributors have cogently explained hundreds of useful facets in the transfer pricing field that have taken others volumes to articulate. The busy professional should consider this book in his or her quest for knowledge in the scintillating tax specialty." -Charles L. Crowley, Partner ITS/Customs and International Trade Practice, Ernst & Young, LLP "Transfer Pricing Methods . . . should become a standard tool for every owner-managed and mid-cap multinational." -Enrique MacGregor, Principal-in-Charge, Transfer Pricing Services Grant Thornton LLP "Bob's vast experience in transfer pricing matters has again been captured between the covers of a book. Thank you, Bob, and your contributing colleagues, for producing another valuable helpmate." -Alan Getz, Vice President and General Manager, Tax Mitsui & Co., Inc. (U.S.A.) "Feinschreiber's current publication is a practical handbook that presents transfer pricing tools that can assist tax professionals of mid-sized companies to optimize profits, manage cash flows, and moderate taxes in a defensible manner." -Per H. Hasenwinkle, National Practice Leader, Transfer Pricing BDO Seidman, LLP

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017

Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264265120
Total Pages : 612 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 by : OECD

Download or read book OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 written by OECD and published by OECD Publishing. This book was released on 2017-07-10 with total page 612 pages. Available in PDF, EPUB and Kindle. Book excerpt: This consolidated version of the OECD Transfer Pricing Guidelines includes the revised guidance on safe harbours adopted in 2013, as well as the recent amendments made by the Reports on Actions 8-10 and 13 of the BEPS Actions Plan and conforming changes to Chapter IX.

U.S. Transfer Pricing Sourcebook

Author : Amanda Johnson
Publisher : WorldTrade Executive, Inc.
ISBN 13 : 9781893323698
Total Pages : 124 pages
Book Rating : 4.3/5 (236 download)

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Book Synopsis U.S. Transfer Pricing Sourcebook by : Amanda Johnson

Download or read book U.S. Transfer Pricing Sourcebook written by Amanda Johnson and published by WorldTrade Executive, Inc.. This book was released on 2005-03 with total page 124 pages. Available in PDF, EPUB and Kindle. Book excerpt: U.S. TRANSFER PRICING SOURCEBOOK is a single-volume report designed to advise international finance professionals on the cutting edge tools and techniques being developed and applied by leading consultants. This sourcebook provides strategies on Intercompany Sales, Intercompany Service transactions, Cross-Border licensing, and Cost Sharing agreements.

Transfer Pricing Handbook

Author : Robert Feinschreiber
Publisher : John Wiley & Sons
ISBN 13 :
Total Pages : 878 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Transfer Pricing Handbook by : Robert Feinschreiber

Download or read book Transfer Pricing Handbook written by Robert Feinschreiber and published by John Wiley & Sons. This book was released on 2001 with total page 878 pages. Available in PDF, EPUB and Kindle. Book excerpt: This supplement updates the core volumes, Feinschreiber/Transfer Pricing Handbook, Third Edition (ISBN 0471-406619) and Transfer Pricing International: A Country by Country Guide (ISBN 0471-385239).

Transfer Pricing Handbook

Author : Robert Feinschreiber
Publisher : John Wiley & Sons
ISBN 13 :
Total Pages : 1040 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Transfer Pricing Handbook by : Robert Feinschreiber

Download or read book Transfer Pricing Handbook written by Robert Feinschreiber and published by John Wiley & Sons. This book was released on 2001 with total page 1040 pages. Available in PDF, EPUB and Kindle. Book excerpt: This supplement updates the core volumes, Feinschreiber/Transfer Pricing Handbook, Third Edition (ISBN 0471-406619) and Transfer Pricing International: A Country by Country Guide (ISBN 0471-385239).

Transfer Pricing in the US

Author : Felix I. Lessambo
Publisher :
ISBN 13 : 9789041191960
Total Pages : 240 pages
Book Rating : 4.1/5 (919 download)

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Book Synopsis Transfer Pricing in the US by : Felix I. Lessambo

Download or read book Transfer Pricing in the US written by Felix I. Lessambo and published by . This book was released on 2017 with total page 240 pages. Available in PDF, EPUB and Kindle. Book excerpt: This concise, practical guide to the latest issues in the rapidly evolving legal regime on transfer pricing in the US context fills the need to gain a firm grasp of transfer pricing rules and practice for corporate counsel and practitioners worldwide, enabling them to prepare compliant solutions and strategies and avoid pitfalls. The book begins with a general introduction to transfer pricing and then discusses the current OECD's Transfer Pricing Guidelines, which form the basis for most transfer pricing rules around the world. The book describes in detail the approved methods for tangible and intangible property, cost sharing, services and the best method rule. Then the book discusses functional analysis for the various methods, including the necessary documentation and penalty rules. This book is an indispensable resource for practitioners and academics, and it will be very useful to state tax authorities.

Transfer Pricing

Author : Marc M. Levey
Publisher : CCH Incorporated
ISBN 13 : 9780808021667
Total Pages : 0 pages
Book Rating : 4.0/5 (216 download)

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Book Synopsis Transfer Pricing by : Marc M. Levey

Download or read book Transfer Pricing written by Marc M. Levey and published by CCH Incorporated. This book was released on 2010 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Transfer Pricing in the US

Author : Felix I. Lessambo
Publisher :
ISBN 13 : 9789041191977
Total Pages : pages
Book Rating : 4.1/5 (919 download)

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Book Synopsis Transfer Pricing in the US by : Felix I. Lessambo

Download or read book Transfer Pricing in the US written by Felix I. Lessambo and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

U.S. Transfer Pricing Guide

Author :
Publisher :
ISBN 13 :
Total Pages : pages
Book Rating : 4.:/5 (326 download)

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Book Synopsis U.S. Transfer Pricing Guide by :

Download or read book U.S. Transfer Pricing Guide written by and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Guide to International Transfer Pricing

Author : Dr A. Michael Heimert
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403501715
Total Pages : 1290 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Guide to International Transfer Pricing by : Dr A. Michael Heimert

Download or read book Guide to International Transfer Pricing written by Dr A. Michael Heimert and published by Kluwer Law International B.V.. This book was released on 2018-10-26 with total page 1290 pages. Available in PDF, EPUB and Kindle. Book excerpt: The pricing of goods, services, intangible property and financial instruments within a multi-divisional organization, particularly in regard to cross-border transactions, has emerged as one of the most contentious areas of international tax law. This is due in no small measure to the rise of transfer pricing regulations as governments seek to stem the flow of their tax revenue from their jurisdictions. This thoroughly practical work provides guidance on an array of critical transfer pricing issues. The guide’s relevance is further enhanced by the inclusion of country chapters covering domestic transfer pricing issues in a variety of key national jurisdictions.

A Practical Guide to U. S. Taxation of International Transactions

Author : Robert Meldman
Publisher : Springer
ISBN 13 :
Total Pages : 408 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis A Practical Guide to U. S. Taxation of International Transactions by : Robert Meldman

Download or read book A Practical Guide to U. S. Taxation of International Transactions written by Robert Meldman and published by Springer. This book was released on 1997 with total page 408 pages. Available in PDF, EPUB and Kindle. Book excerpt: Discusses two fundamental principles of US taxation of international transactions, i.e. tax jurisdiction and the source of income rules. Explains how the US taxes the foreign activities of domestic corporations, US citizens and other US persons. Includes chapters on the foreign tax credit, the deemed paid foreign tax credit, transfer pricing, controlled foreign corporations, foreign sales corporations and income tax treaties. Describes how the US taxes the US activities of foreign corporations, non-resident alien individuals, and other foreign persons.

The Fundamentals of U.S. Transfer Pricing

Author : Steve C. Wrappe
Publisher :
ISBN 13 : 9781639052912
Total Pages : 0 pages
Book Rating : 4.0/5 (529 download)

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Book Synopsis The Fundamentals of U.S. Transfer Pricing by : Steve C. Wrappe

Download or read book The Fundamentals of U.S. Transfer Pricing written by Steve C. Wrappe and published by . This book was released on 2022 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Transfer Pricing in One Lesson

Author : Oliver Treidler
Publisher : Springer Nature
ISBN 13 : 3030250857
Total Pages : 145 pages
Book Rating : 4.0/5 (32 download)

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Book Synopsis Transfer Pricing in One Lesson by : Oliver Treidler

Download or read book Transfer Pricing in One Lesson written by Oliver Treidler and published by Springer Nature. This book was released on 2019-09-12 with total page 145 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a concise and pragmatic introduction to transfer pricing. Approaching the subject from an economic and business perspective, it familiarizes the reader with the basic concepts without getting sidetracked by tax law. In turn, the book draws on case studies to demonstrate the identification and application of appropriate transfer pricing methods for the most common intercompany transactions. The intuitive step-by-step guidance, together with integrated Excel-based tools, will equip the reader to ensure compliance with the arm’s length principle and thus to minimize tax risk. Based on the post-BEPS OECD Guidelines, the book’s content is applicable to a global context.