Transfer Pricing Methods
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...
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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 PricingServices 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
PrefacePt. 1Understanding Transfer Pricing1Ch. 1Practical Aspects of Transfer Pricing3Ch. 2Business Facets of Transfer Pricing13Ch. 3General Principles and Guidelines40Ch. 4Transfer Pricing Basics49Pt. 2Applying Specific Transfer Pricing Techniques61Ch. 5Comparable Uncontrolled Price Method, Resale Price Method, and Cost-Plus Method63Ch. 6Comparable Profits Method84Ch. 7Comparable Uncontrolled Transaction Method for Intangibles93Ch. 8Transfer Pricing for Services138Ch. 9Cost Sharing163Ch. 10Profit Methods191Pt. 3Focus on International Transfer Pricing Issues197Ch. 11Foreign-Owned U.S. Corporations Reporting199Ch. 12Organization for Economic Cooperation and Development Guidelines206Ch. 13Transactional Net Margin Method226Pt. 4Avoiding Transfer Pricing Penalties243Ch. 14Transfer Pricing Penalties245Ch. 15Transfer Pricing Penalty Exclusion for Contemporaneous Documentation263Pt. 5Advanced Transfer Pricing Issues277Ch. 16Advanced Transfer Pricing279Ch. 17Unfolding Transfer Pricing Issues292Index313
