Transfer Pricing Methods: An Applications Guide / Edition 1

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Overview

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

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Product Details

  • ISBN-13: 9780471573609
  • Publisher: Wiley, John & Sons, Incorporated
  • Publication date: 3/8/2004
  • Edition number: 1
  • Pages: 320
  • Sales rank: 850,445
  • Product dimensions: 10.00 (w) x 7.00 (h) x 0.81 (d)

Meet the Author

ROBERT FEINSCHREIBER is a practicing attorney and counselor, as well as a former CPA. As a partner in the firm of Feinschreiber & Associates, his clients include foreign-owned U.S. businesses, U.S. exporters, and companies facing international tax issues. He has written and edited many books, including the Transfer Pricing Handbook, Third Edition, Export Handbook, and International Mergers and Acquisitions, all published by Wiley.

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Table of Contents

Preface
Pt. 1 Understanding Transfer Pricing 1
Ch. 1 Practical Aspects of Transfer Pricing 3
Ch. 2 Business Facets of Transfer Pricing 13
Ch. 3 General Principles and Guidelines 40
Ch. 4 Transfer Pricing Basics 49
Pt. 2 Applying Specific Transfer Pricing Techniques 61
Ch. 5 Comparable Uncontrolled Price Method, Resale Price Method, and Cost-Plus Method 63
Ch. 6 Comparable Profits Method 84
Ch. 7 Comparable Uncontrolled Transaction Method for Intangibles 93
Ch. 8 Transfer Pricing for Services 138
Ch. 9 Cost Sharing 163
Ch. 10 Profit Methods 191
Pt. 3 Focus on International Transfer Pricing Issues 197
Ch. 11 Foreign-Owned U.S. Corporations Reporting 199
Ch. 12 Organization for Economic Cooperation and Development Guidelines 206
Ch. 13 Transactional Net Margin Method 226
Pt. 4 Avoiding Transfer Pricing Penalties 243
Ch. 14 Transfer Pricing Penalties 245
Ch. 15 Transfer Pricing Penalty Exclusion for Contemporaneous Documentation 263
Pt. 5 Advanced Transfer Pricing Issues 277
Ch. 16 Advanced Transfer Pricing 279
Ch. 17 Unfolding Transfer Pricing Issues 292
Index 313
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