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Transfer Pricing: Rules Compliance and Controversy (5th Edition)

Transfer Pricing: Rules Compliance and Controversy (5th Edition)

作者： Marc M. Levey; Steven C. Wrappe
出版商： CCH U.S.
ISBN: 9780808053859
出版时间 February 2020
规格： Paperback , 1089 pages
适应领域： U.S. ? 免责申明：
Countri(es) stated herein are used as reference only

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Transfer Pricing: Rules, Compliance and Controversy offers extensive yet clear guidance through the complex maze of U.S. transfer pricing rules. The book is authored by leading experts in the transfer pricing scene. Throughout the book, the authors 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.
- Chapter 1—Introduction
- Chapter 2—General Principles of Code Sec. 482
- Chapter 3—Methods for Transfers of Tangible Property
- Chapter 4—Methods for Transfer of Intangible Property
- Chapter 5—Intercompany Services
- Chapter 6—Intercompany Loans and Advances
- Chapter 7—Penalties
- Chapter 8—The Code Sec. 1059A limitation
- Chapter 9—Overall strategy for compliance and controversy
- Chapter 10—Preparing transfer pricing documentation
- Chapter 11—Examination
- Chapter 12—Post-examination procedural alternatives
- Chapter 13—Advance pricing agreements
- Chapter 14—The OECD approach to transfer pricing
- Chapter 15—Customs valuation issues
- Chapter 16—State transfer pricing
- Marc M. Levey, partner with the New York office of Baker & McKenzie, is a nationally recognized expert in international taxation, particularly in structuring and defending transfer pricing strategies. Acknowledged by Euromoney magazine as one of the "Leading U.S. Tax Attorneys" and by the International Tax Review as one of the "World's Leading Transfer Pricing Advisors," his practice emphasizes transfer pricing and cross-border transactions, tax controversies and litigation, and general corporate and partnership taxation..
- Steven C. Wrappe, is a partner in the Washington, D.C. Office of Mayer, Brown, Rowe & Maw LLP. He has more than 25 years tax experience with 15 years of specialization in transfer pricing and Advance Pricing Agreements (APAs). He has had direct involvement in more than 100 APAs covering a cross-section of industries, transactions and methodologies, and he serves as global or North American transfer pricing adviser to a number of Fortune 500 companies.
  
  He is an internationally-recognized expert on transfer pricing and dispute resolution with numerous speeches and nearly 100 publications on transfer pricing topics to his credit. Recognized by Euromoney and the International Tax Review as a "Leading Transfer Pricing Advisor," he serves as Chair of the Transfer Pricing Committee of the ABA Section of Taxation.
  
  Wrappe is an adjunct professor at the Georgetown University Law Center (Transfer Pricing), and a regular guest lecturer in the LL.M. Program at New York University School of Law.

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