Transfer Pricing Rules and Compliance Handbook

by Marc M. Levey; Steven C. Wrappe; and Kerwin Chung

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Product Description
Transfer Pricing Rules and Compliance Handbook is a valuable overview and introduction for those involved in transfer pricing decisions in the United States, as well as foreign tax and business professionals with a need to deal with U.S. transfer pricing rules. It is the perfect introductory book for practitioners new to transfer pricing issues and business executives and financial managers who need to understand these important principles and rules that impact multinational business entities and operations. The book addresses the growing need for a working level of understanding of transfer pricing concepts. Over the last decade, transfer pricing decisions have become more important to multinational entities. The sheer magnitude of potential adjustments, combined with the ability to trigger cross-border tax disputes and the potential to have a material impact on financial reporting, ensures that transfer pricing will remain an area of continued corporate vigilance. Given the potential for transfer pricing decisions to globally impact tax, financial and operational results, it is important that financial and operational personnel at multinational entities who are making transfer pricing decisions possess the information they need. This book includes topics that will help them to make informed decisions. Such topics include: - the U.S. rules governing transfer pricing - how taxpayers can document transfer pricing determinations to avoid disputes - how to manage a transfer pricing examination - post-examination procedural alternatives to resolve transfer pricing disputes, and much more. This book also discusses the advance pricing agreement (APA) procedure, an approach whereby taxpayers prospectively agree with one or more tax authorities regarding their transfer pricing determinations. Finally, it covers the impact of transfer pricing on other tax issues, the impact of transfer pricing on non-tax regulatory issues including customs valuations, Section 404 of

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