"... presents a case study in selecting a transfer pricing methodology and analyzes three alternative strategies: advance pricing agreements, cost sharing arrangements, and the use of joint ventures. The Detailed Analysis consists of Chapters 8 and 9 of the Tax Management Transfer Pricing Portfolio Series.
Author: Marc M. Levey, Formerly published in Washington, D.C., 1997-2007.
Bibliography, etc. Note
Includes bibliographical references.
Formatted Contents Note
Detailed analysis. Chapter 8: advance pricing agreements 8:I. Organization of this Chapter 8:II. The APA Process in General 8:III. Factors to Consider in Deciding Whether to Seek an APA 8:IV. APAs as an Alternative Dispute Resolution Mechanism 8:V. IRS Guidance The APA Process in Transition: From Rev. Proc. 91-22 to Rev. Proc. 2015-41 8:VI. The Prefiling Conference 8:VII. The APA Application and Supporting Data 8:VIII. Negotiating the APA 8:IX. Foreign APA Considerations 8:X. Administering the APA. Chapter 9: Cost Sharing Arrangements 9:I. What Is a Cost Sharing Arrangement? 9:II. Cost-Benefit Analysis of a Cost Sharing Arrangement 9:III. International Aspects of Cost Sharing Arrangements 9:IV. The 1995 and Proposed 2005 U.S. Cost Sharing Rules 9:V. Qualified Cost Sharing Arrangement 9:VI. Participant 9:VII. Intangible Development Costs 9:VIII. Anticipated Benefits 9:IX. Cost Allocations 9:X. Allocations of Income, Deductions or Other Items to Reflect Transfers of Intangibles (Buy-In) 9:XI. Character of Payments Made Pursuant to a QCSA 9:XII. Accounting Requirements 9:XIII. Administrative Requirements 9:XIV. Effective Date 9:XV. IRS Authority to Impose Cost Sharing 9:XVI. Coordination with Advance Pricing Agreements 9:XVII. The 2011 Final Regulations Revised U.S. Cost Sharing Rules Working Papers.
Digital File Characteristics
System Details Note
Mode of access: World Wide Web.
Source of Description
Description based on contents viewed on September 12, 2016; title from portfolio description page.
Available in Other Form
Print version: Patton, Michael F. Transfer pricing. Washington, D.C. : Tax Management Inc., -