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  • 作      者: Robert T. Cole (Original Principal Author)&Wi
  • 出版时间: 2006-00-00
  • 语      言: 英文
  • 价      格: 4040 HKD
内容简介
Transfer pricing is one of the hottest topics in international tax today. Transfer pricing rules are an inescapable part of doing business internationally, and this third edition of Practical Guide to U.S. Transfer Pricing provides an in-depth analysis of the U.S. rules. This product is designed to help multinationals cope with the U.S. transfer pricing rules and procedures, taking into account the international norms established by the Organisation for Economic Co-operation and Development (OECD). It is also designed for use by tax administrators, both those belonging to the U.S. Internal Revenue Service and those belonging to the tax administrations of other countries, and tax professionals in and out of government, corporate executives, and their non-tax advisors, both American and foreign.

The U.S. rules are presented along with ideas on how to apply them in a common-sense fashion in a multi-jurisdictional world. A few of the highlights in the latest update to the treatise are as follows:

The most important development in U.S. transfer pricing in the year ended in July 2013 is the strengthening of the IRS's capability to enforce the U.S. transfer pricing rules.
We examine Transfer Pricing Operations' three groups: the Advance Pricing and Mutual Agreement group (APMA), the Transfer Pricing Practice, and the International Practice Networks (IPNs).
We note the 2014 budget proposal, carried over from 2013, of the Obama administration limiting the shifting of income through intangible property transfers, which would expand the scope of intangible property for purposes of IRC Sections 367(d) and 482 to include ''workforce in place, goodwill, and going concern value.''
We discuss the new ''Rapid Appeals Process,'' which is available for controversies that have arisen in an LB&I audit. It contemplates that Appeals, the examination team, and the taxpayer will discuss the case jointly in a single preopening conference in an effort to resolve the outstanding issues before the case is considered further by Appeals.
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