Practical Guide to U.S. Transfer Pricing

Commentary

This third edition of the Practical Guide to US Transfer Pricing is an essential resource for tax professionals acting for multinational corporations, providing an in-depth exploration of the US transfer pricing rules and comparing them with the OECD Transfer Pricing Guidelines.

Highlights include the strengthening of the Internal Revenue Service's capability to enforce the US transfer pricing rules, discussion of the temporary cost sharing regulations finalized in 2012, Supreme Court cases regarding the authority of the US Treasury to issue regulations contrary to earlier court decisions, analysis of the more receptive approach of US Immigration and Customs Enforcement to transfer pricing documentation and advance pricing agreements, and the many changes in IRS examination procedures.


SOURCE CURRENCY
December 2019