Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice / Edition 1

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This book analyzes the disparities both between federal statutes and regulations, and regulations and administrative practices, in two highly controversial areas of corporate tax policy: intra-company transfer pricing and intangible asset valuations. It addresses issues that can mean hundreds of millions of dollars to individual corporations, and a significant fraction of the federal government's revenue base.
Tax practitioners and consultants who are understandably frustrated in their efforts to divine the IRS's reasoning in transfer pricing and valuation issues will find the book very useful. It will also find an audience among elected representatives, other public officials, and tax lobbyists in the process of evaluating existing corporate tax policy or formulating alternative tax policies. In addition, the book is a useful reference for academics studying international taxation, public finance, and treaty compliance.

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Product Details

  • ISBN-13: 9780792393924
  • Publisher: Springer Netherlands
  • Publication date: 3/5/1999
  • Edition description: 1994
  • Edition number: 1
  • Pages: 284
  • Product dimensions: 0.81 (w) x 9.21 (h) x 6.14 (d)

Table of Contents

Preface. I: Legislation and Regulations. 1. Introduction. 2. Transfer Pricing and Valuation Regulations. II: Transfer Pricing and Valuation Regulations in Practice. 3. The Cost-Plus Method. 4. The Resale Price Method. 5. Cost-Sharing Agreements. 6. Intra-Company Royalty Agreements. 7. Valuation of Intangible Assets: Section 338. 8. Conclusions and Policy Recommendations. Index.
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