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Transfer Pricing: Rules, Compliance and Controversy

Publisher: CCH
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Description

CCH Incorporated
Transfer pricing is a reality that has become hard to avoid in global business. It has attracted 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.

Transfer Pricing: Rules, Compliance and Controversy, a brand-new practice-oriented resource from CCH, offers extensive yet clear guidance through the complex maze of U.S. transfer pricing rules. The book is authored by Marc M. Levey of Baker & McKenzie and Steven C. Wrappe of Deloitte & Touche LLP, leading experts in the transfer pricing scene. Throughout 19 chapters, Levey and Wrappe 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.

Levey and Wrappe's practical coverage and approach includes:

  • A comprehensive analysis of the U.S. rules, case law and guidance regarding transfer pricing for:
    • Tangible goods
    • Intangibles
    • Services
  • Demonstrations of complex cost-sharing planning principles, including buy-in
  • Cutting-edge e-commerce transfer pricing issues
  • Practical discussions of the U.S. penalty and documentation rules
  • The common sense approach to documentation with checklists, questionnaires and model report
  • Comparisons of U.S. penalty rules to those of other important countries
  • Explanation of the overlap between transfer pricing and Customs valuation issues
  • Analysis of new Customs rulings based on an APA
  • An 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-examination opportunities to resolve the dispute
    • Appeals
    • ADR
    • Litigation
    • APAs and Competent Authority

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.

The thorough elaboration of the topics discussed, paired with clear and understandable writing, makes this new volume an excellent reference for both the experienced practitioner and the newcomer to the transfer pricing field.

Table of Contents

Excerpts

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Product# CC005316P0100D
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