Transfer pricing : competent authority consideration / Brian S. Gleicher, Esq., White & Case LLP, Washington, D.C.
2011
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Items
Details
Author
Title
Transfer pricing : competent authority consideration / Brian S. Gleicher, Esq., White & Case LLP, Washington, D.C.
Added Corporate Author
Imprint
Arlington, VA : Tax Management, [2011]-
Description
1 online resource.
Frequency
Updated irregularly
Series
Tax management portfolios ; 6928.
Formatted Contents Note
Detailed analysis. I. Introduction
II. Treaty basis for competent authority relief
III. Other limitations on applicability and availability of competent authority relief
IV. U.S. implementation of the competent authority procedure
V. Revenue procedure 2015-40
current IRS guidance
VI. Considerations in requesting competent authority assistance
VII. Negotiation of the agreement between the competent authorities
VIII. Procedures for requesting competent authority assistance
IX. Interrelated and ancillary issues
X. Special considerations in U.S.-initiated transfer pricing cases
XI. Special considerations in foreign-initiated transfer pricing cases
XII. Taxpayer-initiated competent authority request
XIII. Finalization of competent authority agreement
Working papers.
II. Treaty basis for competent authority relief
III. Other limitations on applicability and availability of competent authority relief
IV. U.S. implementation of the competent authority procedure
V. Revenue procedure 2015-40
current IRS guidance
VI. Considerations in requesting competent authority assistance
VII. Negotiation of the agreement between the competent authorities
VIII. Procedures for requesting competent authority assistance
IX. Interrelated and ancillary issues
X. Special considerations in U.S.-initiated transfer pricing cases
XI. Special considerations in foreign-initiated transfer pricing cases
XII. Taxpayer-initiated competent authority request
XIII. Finalization of competent authority agreement
Working papers.
Summary
"Tax Management Portfolio, Transfer Pricing: Competent Authority Consideration, No. 6928, discusses the considerations that the taxpayer should take into account in requesting competent authority assistance, negotiation of the competent authority agreement, the taxpayer's strategy, and finalization of the agreement. It also examines the costs and benefits of seeking a competent authority agreement."
Note
Previously published as Tax Management portfolio 892, <aug. 9, 2011>.
Bibliography, etc. Note
Includes bibliographical references.
Source of Description
Description based on contents viewed on December 10, 2019; title from description page.
Location
www
Available in Other Form
Print version: Gleicher, Brian S. Transfer pricing. Arlington, VA : Tax Management, [2019]-
Linked Resources
Alternate Title
BNA Premier package.
Language
English
Record Appears in