Practical guide to U.S. transfer pricing
By: editor and principal author, Robert T. Cole.
Edition: 3rd ed.
Publisher: LexisNexis Matthew Bender
Published: 2006
Place of publication: Newark, NJ
Language: eng
Number of pages: 25
Subjects: International business enterprises -- Taxation -- Law and legislation -- United States; Transfer pricing -- Taxation -- Law and legislation -- United States; Transfer pricing -- Law and legislation -- United States
Other titles: Practical guide to United States transfer pricing
Notes: Includes bibliographical references and index.
Table of contents: title: Overview of transfer pricing; title: Framework for U.S. transfer pricing analysis under treasury regulation Section 1.482-1; title: Determination of related person status; title: Finding and selecting comparables; title: Comparable uncontrolled price (CUP) method; title: Resale price method (RPM) and alternatives to traditional buy-sell; title: Cost plus method and location savings; title: Transfer pricing rules and methods for intangible property; title: Comparable profits method; title: Profit split methods; title: Unspecified methods; title: Functional analysis and choosing the best method; title: Cost sharing arrangements; title: Transfer pricing for services under the 1968 treasury regulations and the 2006 temporary treasury regulations; title: Determining arm's length interest and rent; title: Financial industry transfer pricing issues; title: Second-level effects of transfer pricing adjustments; title: Documented self-compliance to avoid penalties under IRC section 6662(e); title: Advance pricing agreements (APAS); title: IRC sections 6038A and 6038C : record-keeping, record production, and reporting for foreign-owned groups; title: Examination and appeals; title: Competent authority to avoid double or excessive taxation from transfer pricing adjustments; title: Transfer pricing litigation; title: Relationship of section 482 to other code sections; title: Transfer pricing effects of customs actions and customs effects of transfer pricing actions; title: State tax transfer pricing issues; title: International strategy for transfer pricing compliance : a checklist for multinationals.