Feinschreiber Transfer Pricing Methods

An Applications Guide
1. Auflage 2004
ISBN: 978-0-471-65123-9
Verlag: John Wiley & Sons
Format: PDF
Kopierschutz: Adobe DRM (»Systemvoraussetzungen)

E-Book, Englisch, 336 Seiten, E-Book

Advanced praise for Transfer Pricing Methods
"Feinschreiber and a team of renowned executives have provided thedefinitive transfer-pricing guide to this challenging area. At atime when many companies are reviewing documents, policies, andprocedures, it's wonderful to have a concise, clearly writtenreference focused on what may be the most critical corporate taxissue."
-Charles R. Goulding, Managing Director, Tax
Cooper Industries, Inc.
"It is refreshing to find a treatise on transfer pricing thatcombines practical business considerations, economic theory, and adiscussion of technical tax rules in a way that is meaningful notonly for large corporate enterprises but also small andmedium-sized businesses."
-Vikram A. Gosain, JD, CPA, Director of Transfer Pricing
General Electric Capital Corporation
"This well-written book will be useful both to attorneys new to thepractice area and to older hands. It includes very helpfuldiscussions on valuation issues that will be particularly usefulfor in-house counsel and accountants."
-Joseph C. Mandarino, Partner
Troutman Sanders, LLP
"Feinschreiber and his contributors have cogently explainedhundreds of useful facets in the transfer pricing field that havetaken others volumes to articulate. The busy professional shouldconsider this book in his or her quest for knowledge in thescintillating tax specialty."
-Charles L. Crowley, Partner
ITS/Customs and International Trade Practice, Ernst & Young,LLP
"Transfer Pricing Methods . . . should become a standard tool forevery owner-managed and mid-cap multinational."
-Enrique MacGregor, Principal-in-Charge, Transfer PricingServices
Grant Thornton LLP
"Bob's vast experience in transfer pricing matters has again beencaptured between the covers of a book. Thank you, Bob, and yourcontributing colleagues, for producing another valuablehelpmate."
-Alan Getz, Vice President and General Manager, Tax
Mitsui & Co., Inc. (U.S.A.)
"Feinschreiber's current publication is a practical handbook thatpresents transfer pricing tools that can assist tax professionalsof mid-sized companies to optimize profits, manage cash flows, andmoderate taxes in a defensible manner."
-Per H. Hasenwinkle, National Practice Leader, TransferPricing
BDO Seidman, LLP

Autoren/Hrsg.

Feinschreiber, Robert

Inhaltsverzeichnis

Preface.
PART ONE: UNDERSTANDING TRANSFER PRICING.
Chapter 1. Practical Aspects of Transfer Pricing.
Chapter 2. Business Facets of Transfer Pricing.
Chapter 3. General Principles and Guidelines.
Chapter 4. Transfer Pricing Basics.
PART TWO: APPLYING SPECIFIC TRANSFER TECHNIQUES.
Chapter 5. Comparable Uncontrolled Price Method, Resale PriceMethod, and Cost-Plus Method.
Chapter 6. Comparable Profits Method.
Chapter 7. Comparable Uncontrolled Transaction Method forIntangibles.
Chapter 8. Transfer Pricing for Services.
Chapter 9. Cost Sharing.
Chapter 10. Profit Methods.
PART THREE: FOCUS ON INTERNATIONAL TRANSFER PRICING ISSUES.
Chapter 11. Foreign-Owned U.S. Corporations Reporting.
Chapter 12. Organization for Economic Cooperation andDevelopment Guidelines.
Chapter 13. Transactional Net Margin Method.
PART FOUR: AVOIDING TRANSFER PRICING PENALTIES.
Chapter 14. Transfer Pricing Penalties.
Chapter 15. Transfer Pricing Penalty Exclusion forContemporaneous Documentation.
PART FIVE: ADVANCED TRANSFER PRICING ISSUES.
Chapter 16. Advanced Transfer Pricing.
Chapter 17. Unfolding Transfer Pricing Issues.
Index.

Über Autor(innen)

ROBERT FEINSCHREIBER is a practicing attorney and counselor, as well as a former CPA. As a partner in the firm of Feinschreiber & Associates, his clients include foreign-owned U.S. businesses, U.S. exporters, and companies facing international tax issues. He has written and edited many books, including the Transfer Pricing Handbook, Third Edition, Export Handbook, and International Mergers and Acquisitions, all published by Wiley.