Transfer pricing : international joint ventures / R. Arnold Handler, Esq. (Tax Attorney/Consultant, New York, New York).
2016
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Details
Title
Transfer pricing : international joint ventures / R. Arnold Handler, Esq. (Tax Attorney/Consultant, New York, New York).
Added Corporate Author
Imprint
Arlington, VA : Tax Management Inc., [2016]-
Copyright
©2016-
Description
1 online resource.
Frequency
Updated irregularly.
Series
Tax management portfolios ; 6906.
Formatted Contents Note
Detailed Analysis
I. Introduction: "Control"
II. Legal Framework
III. Establishing Absence of Common Control and Arm's-Length Transactions
IV. Hidden or "Creeping" Control
V. Joint Venture Pricing as an Arm's-Length Comparable
VI. Additional Tax Planning Issues
VII. Summary of Key Reporting Obligations
VIII. Conclusions
Working papers.
I. Introduction: "Control"
II. Legal Framework
III. Establishing Absence of Common Control and Arm's-Length Transactions
IV. Hidden or "Creeping" Control
V. Joint Venture Pricing as an Arm's-Length Comparable
VI. Additional Tax Planning Issues
VII. Summary of Key Reporting Obligations
VIII. Conclusions
Working papers.
Summary
"...discusses tax issues pertinent to international joint ventures, including [section] 482 issues, such as: control, hidden or “creeping” control, acting in concert, and burden of proof. Other tax issues discussed include those in the joint venture context, such as: choice of entity, formation of, and outbound transfers to, joint venture corporate and partnership vehicles (including the issuance of proposed regulations under [section] 367(a) and [section] 367(d) for foreign corporations and Notice 2015-54 for partnerships), check-the-box rules, blocker corporations, piercing the corporate veil, sham treatment, taxation of operating income, reporting requirements, repatriation of income, foreign tax credit planning, and joint venture termination."
Bibliography, etc. Note
Includes bibliographical references.
Source of Description
Description based on contents viewed on September 12, 2016; title from portfolio description page.
Location
www
Available in Other Form
Print version: Handler, R. Arnold, 1940- Transfer pricing. Arlington, VA : Tax Management Inc., [2016]-
Linked Resources
Alternate Title
Tax Management Portfolios.
Language
English
Separated From
Patton, Michael F. Transfer pricing. Arlington, VA : Tax Management, [1997]
Record Appears in