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.

Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice PDF

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