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| Practical Aspects of Transfer Pricing | |
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| Introduction to Intercompany Transfer Pricing | |
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| Underlying Policy of the Regulations | |
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| Changing The Transfer Pricing Process | |
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| General Principles and Guidelines | |
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| Applying Functional Analysis | |
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| Risk and Its Consequences | |
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| The Best Method Rule | |
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| The Arm's Length Range | |
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| Finding and Analyzing Comparable Financial Data | |
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| Analyzing Sales Of Tangible Property | |
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| Updating the Traditional Tangible Property Transfer Rules: An Update | |
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| The Comparable Uncontrolled Price Method | |
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| Resale Price Method | |
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| Cost Plus Method | |
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| Applying New Transfer Pricing Methods | |
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| Cost Sharing | |
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| The Comparable Profits Method | |
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| Transactional Net Margin Method | |
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| Financial Transactions and Transfer Pricing | |
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| Foreign Exchange Adjustment Under Section 482 | |
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| Special Circumstances in Transfer Pricing | |
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| OECD Guidelines | |
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| Arm's Length Markups for Maquiladoras | |
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| Intangibles And Services | |
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| Comparable Uncontrolled Transaction Method for Intangibles | |
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| Intangible Asset Valuation and Royalty Rates | |
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| The Role of Rate Return in Section 482 Analyses | |
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| OECD Rules for Intangible Property | |
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| Transfer Pricing for Services | |
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| Apportioning Taxable Income | |
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| Profit Split Methodologies | |
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| Foreign Sales Corporation Quantitative Transfer Pricing Methods | |
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| State Tax Implications | |
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| Volume II Penalties | |
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| Transfer Pricing Penalties | |
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| Transfer Pricing Penalty Exclusion for Contemporaneous Documentation | |
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| Foreign-Owned U.S | |
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| Corporations | |
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| Overview of Foreign-Owned U.S | |
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| Corporations | |
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| Recordkeeping and Reporting | |
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| Multiple Thresholds | |
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| Reporting Requirements | |
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| General Record Maintenance Requirements | |
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| Using the Safe Harbor Provisions | |
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| Significant Industry Segment Test | |
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| High Profit Test | |
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| Structuring Record Maintenance Agreements | |
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| Penalties | |
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| 22Limited Agency22 Agreements | |
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| Summons Procedure | |
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| Formal Document Request Procedure | |
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| Preparing For Audits And Litigation | |
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| Understanding the Transfer Pricing Examinations | |
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| Litigating Transfer Pricing Cases | |
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| Use of Experts in Transfer Pricing Cases | |
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| Third-Party Information in Transfer Pricing Cases | |
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| Competent Authority | |
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| Aribtration of Transfer Pricing Disputes | |
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| Using Advance Pricing Agreements for Transfer Pricing | |
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| Foreign Tax Credit Implications of Transfer Pricing | |
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| Coordinating Tax And Nontax Issues | |
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| Importing Merchandise-The | |