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Preface=xv

PART ONE. Understanding Transfer Pricing=1

CHAPTER 1. Practical Aspects of Transfer Pricing=3

Comparison or Division=3

Relationship of the Parties=4

Overview of the Tax Changes=4

Approaches to Transfer Pricing=5

Penalties=5

Transfer Pricing Strategies=8

Parameters to Substantiating Transfer Pricing=10

CHAPTER 2. Business Facets of Transfer Pricing=13

Basic Distinctions=13

Selecting a Pricing Strategy=14

Division and Profit Center Accounting=14

Autonomous Transactions=15

Vertical Integration and Mandated Transactions=17

Mandated Sales versus Autonomous Sales=18

Administrative Aspects of Transfer Pricing=19

Corporate and Divisional Vantage Points=21

Determining the Number of Profit Centers=26

By-Products and Joint Products=27

Costing Alternatives=27

Applying Mandated Full-Cost Transfer Pricing=28

Full Standard Cost Transfer Prices=28

Behind the Standard Cost System=29

Mandated Market-Based Transfer Pricing=30

Cost-Plus Markups=32

Applying the Resale Method to Intracomgany Transfers=33

Transfer Pricing Implications for Autonomous Business Units=33

Conclusion=39

CHAPTER 3. General Principles and Guidelines=40

Background=40

Overview=40

Best Method Rule=41

Comparability Analysis=43

Arm's-Length Range=47

CHAPTER 4. Transfer Pricing Basics=49

Transfer Pricing as a Decision-Making Process=49

Tax and Nontax Considerations=49

Ascertaining Who Is at Risk=50

Foreign Country Participation in Transfer Pricing=50

Basics of the Transfer Pricing Inquiry=51

Transfer Pricing Reference Materials=51

Transfer Pricing Methodologies=51

Transfer Pricing Penalties in the United States=54

Foreign-Owned Businesses Doing Business in the United States=56

Introducing the Advance Pricing Agreement Process=59

PART TWO. Applying Specific Transfer Pricing Techniques=61

CHAPTER 5. Comparable Uncontrolled Price Method, Resale Price Method, and Cost-Plus Method=63

Comparable Uncontrolled Price Method=63

Resale Price Method=69

Cost-Plus Method=78

Conclusion=83

CHAPTER 6. Comparable Profits Method=84

No Safe Harbor=84

Best Method Rule=84

Comparable Profits Method=85

Comparability=87

CPM Examples=89

Conclusion=92

CHAPTER 7. Comparable Uncontrolled Transaction Method for Intangibles=93

General Principles and Guidelines=94

Eligible Methods=95

"Intangible" and Its Definitions=95

Comparable Uncontrolled Transaction Method=97

Comparison of the Transactions=101

Comparable Intangible Property=103

Comparable Circumstances=105

Examples=106

Applying Unspecified Methods for Intangible Property=111

Coordination Between Tangible Property and Intangible Property=114

Special Rules for Transfers of Intangible Property=115

Form of the Consideration=115

Periodic Adjustments=115

Exceptions to Periodic Adjustment Provisions=116

Applying the Periodic Adjustment Rule=124

Ownership of the Intangible Property=128

Intangible Ownership Examples=131

Limits on Consideration=133

Lump Sum Payments=134

Applying the Lump Sum Payment Rule=135

Planning Opportunities=137

Conclusion=137

CHAPTER 8. Transfer Pricing for Services=138

Overview=138

Characterization Considerations=140

Implementing the Services-Property Distinction=141

Ancillary and Subsidiary Services=141

Collateral Concerns=142

Whose Expense Is It?=143

When Arm's Length Can Equal Cost=149

Fair Market Value of Services=155

Future Developments=162

CHAPTER 9. Cost Sharing=183

Conceptual Overview=163

Background=163

Treasury's Concerns=163

Historical Perspective=164

Scope, Application, and Limitations of the Final Regulations=166

Qualified Cost-Sharing Arrangement Defined=168

Controlled and Uncontrolled Participants Distinguished=169

Costs=173

Benefits=176

Measuring Benefits=177

Comparing Projected to Actual Benefits=180

Testing Projected to Actual Benefits=182

Consequences or Failing the 20 Percent Test=184

Buy-Ins and Buyouts=186

Character of Payments=189

Conclusion=190

CHAPTER 10. Profit Methods=191

Changes in the Regulations=191

Basic Premise for the Use of Profit Splits=191

Comparable Profit Split Method=192

Residual Profit Method=193

Best Method Analysis for the Profit Split Approach=195

PART THREE. Focus on International Transfer Pricing Issues=197

CHAPTER 11. Foreign-Owned U.S. Corporations Reporting=199

Background=199

Regulations=200

Parties Affected=200

Reporting Corporations and Related Parties=201

Tax Reporting Requirements=201

Records and Computations=202

Penalties=203

Mandatory Agency Agreements=203

Summons Procedure=204

Conclusion=204

CHAPTER 12. Organization for Economic Cooperation and Development Guidelines=206

History=207

Access to the Guidelines=208

Organization of the Guidelines=208

Definitions=210

Arm's-Length Standard=210

Comparability=211

Arm's-Length Range=212

Transfer Pricing Methods=213

Transfer Pricing Administration=217

Documentation=219

Intangible Property=220

Services=222

Cost Contribution Arrangement(CCA)=223

CHAPTER 13. Transactional Net Margin Method=226

Introduction to Transactional Net Margin Method=226

Weaknesses and Strengths of TNMM=235

Comparison with TNMM and Comparable Profits Method=236

Conclusion=241

PART FOUR. Avoiding Transfer Pricing Penalties=243

CHAPTER 14. Transfer Pricing Penalties=245

Planning=245

Overview=246

Determination of an Underpayment=246

Transactional Penalty=248

Net Adjustment Penalty=251

Setoff Allocation Rule=253

Net Adjustment Penalty Examples=254

Net Section 482 Exculpatory Provisions=256

Application of a Specified Section 482 Method=257

Specified Method Requirement=257

Documentation Requirements=262

CHAPTER 15. Transfer Pricing Penalty Exclusion for Contemporaneous Documentation=263

Overview=264

General Requirements for Specified Section 482 Methods=265

Principal Documents=267

Background Documents=271

Tax Return Documentation=274

Documenting Unspecified Methods=275

Conclusion=276

PART FIVE. Advanced Transfer Pricing Issues=277

Chapter 16. Advanced Transfer Pricing=279

Proposals for Revising the Transfer Pricing Audit Structure=279

Using Data Sources=279

Cost Issues, Excess Capacity, and Cost Structures Overseas=281

Advance Pricing Agreements=282

Gray Market Considerations=283

Corporate Goals and Structure=285

Determining Who Owns the Intangibles=285

Life-Cycle Business Analysis=287

Overreliance on External Data=288

Dependence on SIC Code Analysis=289

Selection of the Best Transfer Pricing Method=291

CHAPTER 17. Unfolding Transfer Pricing Issues=292

"Comparison of Functions Employed" Methodology=292

Using Total Operating Expenses=295

Tax Malpractice Attorney as Your Ally=296

Developing the Standard Initial Transfer Pricing Information Document Request=297

Transfer Pricing Information Document Request for Acquisitions=303

Proposed Second Standard Transfer Pricing Information Document Request=308

Index=313

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Transfer pricing methods : an applications guide 이용현황 표 - 등록번호, 청구기호, 권별정보, 자료실, 이용여부로 구성 되어있습니다.
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0001077008 658.816 F299t 서울관 서고(열람신청 후 1층 대출대) 이용가능

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알라딘제공
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

New feature

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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