Transfer pricing and valuation in corporate taxation :federal legislation vs. administrative practice
- 作者: King, Elizabeth A.,
- 出版: Boston : Kluwer Academic Publishers ©1994.
- 稽核項: 1 online resource (xvii, 284 pages).
- 標題: Intangible property Taxation. , Intangible property Valuation. , International business enterprises Taxation -- Law and legislation. , Electronic books. , TaxationLaw and legislation. , Taxation , International business enterprises Taxation -- Law and legislation -- United States. , Intangible property Taxation -- United States. , Biens incorporels , Transfer pricing Taxation -- Law and legislation. , Valuation , Transfer pricing Accounting. , Taxation. , Transfer pricing , Prix de cession interne , TaxationLaw and legislation , Comptabilité. , Prix de cession interne Comptabilité. , Intangible property , Biens incorporels Impôts -- États-Unis. , LAW Taxation. , Valuation. , Accounting. , International business enterprises , Intangible property Valuation -- United States. , United States. , Impôts , LAW , Transfer pricing Taxation -- Law and legislation -- United States.
- ISBN: 0306482185 , 9780306482182
- ISBN: 0792393929 , 9780792393924
- 試查全文@TNUA:
- 附註: Includes index. Cover -- Table of Contents -- Preface -- I Legislation and Regulations -- 1 Introduction -- 2 Transfer Pricing and Valuation Regulations -- 2.1 Transfer Pricing Regulations: Internal Revenue Code Section 482 -- 2.2 Transfer Pricing Regulations for Possessions Corporations: Internal Revenue Code Section 936(h) -- 2.3 Concurrent and Subsequent Developments in Transfer Pricing -- 2.4 Institutional Dispute Resolution Procedures and Competent Authority Proceedings -- 2.5 Valuation of Acquired Assets for Tax Purposes: Internal Revenue Code Section 338 -- Appendix A: Summary of Coordinated Issue Papers -- II Transfer Pricing and Valuation Regulations in Practice -- 3 The Cost-Plus Method -- 3.1 Background -- 3.2 Cost-Plus Case 1: Leather Goods -- 3.3 Cost-Plus Case 2: Consumer Electronics -- 3.4 Critique of the Cost-Plus Method: 1968 Regulations and 1993 Temporary Regulations -- 3.5 The Broader Setting -- 4 The Resale Price Method -- 4.1 Background -- 4.2 A Resale Price Issue: Electronic Home Entertainment Products -- 4.3 Critique of Resale Price Provisions -- 5 Cost-Sharing Agreements -- 5.1 Background -- 5.2 Cost-Sharing Case 1: Scientific and Analytical Instruments -- 5.3 Cost-Sharing Case 2: Specialized Medical Equipment -- 5.4 Cost-Sharing Case 3: Telecommunications Products -- 5.5 Critique of Proposed Section 482 Cost-Sharing Provisions -- 6 Intra-Company Royalty Agreements -- 6.1 Background -- 6.2 An Intra-Company Royalty Issue: Licensed Process Technology -- 7 Valuation of Intangible Assets: Section 338 -- 7.1 Valuation of Patient Relationships -- 7.2 Valuation of Advertiser and Subscriber Lists -- 7.3 Valuation of Product Endorsements -- 8 Conclusions and Policy Recommendations -- 8.1 The 1993 Temporary Regulations: Two Steps Forward, One Step Back -- 8.2 Proposed Revisions to the 1993 Temporary and Proposed Section 482 Regulations -- 8.3 Lessons from Section 338 -- 8.4 Proposed Institutional Changes.
- 摘要: This book analyzes the disparities both between federal statutes and regulations, and regulations and administrative practices, in two highly controversial areas of corporate tax policy: intra-company transfer pricing and intangible asset valuations. It addresses issues that can mean hundreds of millions of dollars to individual corporations, and a significant fraction of the federal government's revenue base. Tax practitioners and consultants who are understandably frustrated in their efforts to divine the IRS's reasoning in transfer pricing and valuation issues will find the book very useful. It will also find an audience among elected representatives, other public officials, and tax lobbyists in the process of evaluating existing corporate tax policy or formulating alternative tax policies. In addition, the book is a useful reference for academics studying international taxation, public finance, and treaty compliance.
- 電子資源: https://dbs.tnua.edu.tw/login?url=https://search.ebscohost.com/login.aspx?direct=true&scope=site&db=nlebk&AN=99514
- 系統號: 005307475
- 資料類型: 電子書
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- 引用網址: 複製連結
Transfer Pricing and Valuation in Corporate Taxation analyzes the disparities between both federal statutes and regulations, and r- ulations and administrative practice, in a highly controversial area of corporate tax policy: intra-company transfer pricing for tax p- poses. It addresses issues that often mean millions of dollars to in- vidual corporations, and a significant fraction of the federal gove- ment’s revenue base. These disparities between law, regulations, and administrative practice are concerning on a number of grounds. First, they - pose considerable economic costs by inducing corporations to engage in a variety of “rent-seeking” activities designed to reduce their - pected tax liabilities, and by requiring the IRS to devote still more to enforcement efforts that are very often futile. Second, they are in- ; herently undemocratic. Administrative practice is currently ad hoc by relying on dispute resolution procedures that can and do yield very different settlements on disputed tax issues from one case to another, the IRS often ends up treating similarly situated cor- rations very differently. Moreover, to the extent that the disp- ity between statute and implementation reflects the IRS’s failure to carry out Congress’ will, the laws passed by duly elected officials are effectively being superseded by administrative procedure, developed incrementally by individuals who are not answerable to an electorate.
來源: Google Book
來源: Google Book
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