Under the Kyoto Protocol, it is possible for developed countries to simply buy off the cost of their pollution from less developed economies that do not put out their permitted quota of harmful substances into the atmosphere. This mechanism is fraught with both moral and practical difficulties, writes Darryl D'Monte.

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Dewey Library - HF5416.5.S584 2016

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Available: August 2010

Authors: Marc M. Levey J.D., Steven C. Wrappe J.D., CPA

Transfer Pricing: Rules, Compliance and Controversy offers extensive yet clear guidance through the complex maze of U.S. transfer pricing rules. The book is authored by leading experts in the transfer pricing scene. Throughout the book, the authors cover all aspects of transfer pricing relevant to the practitioner, starting with general legal principles and apportionment methods, then moving on to more specific subjects such as transfers of tangible vs. intangible goods and the impact of e-commerce and U.S. customs on transfer pricing, and finally exploring highly practical matters like procedural strategies and post-examination procedures.  

The book's practical coverage and approach include:

• Comprehensive analysis of the U.S. rules, case law and guidance on  transfer pricing for tangible   goods, intangibles, and services
• Complex cost-sharing planning principles, including buy-in
• Cutting edge e-commerce transfer pricing issues
• U.S. penalty and documentation rules
• Documentation with checklists, questionnaires and model report
• U.S. penalty rules compared to those of other important countries
• Overlap between transfer pricing and Customs valuation issues
• Customs ruling based on an APA
• In-depth, step-by-step analysis of the favored approach to transfer pricing controversy, including:
  • Developing a substantive/procedural strategy (with detailed flow-chart)
  • Preparing for examination
  • Identifying post-examination opportunities to resolve the dispute

Special appendices provide a variety of "practice tools" designed to facilitate the understanding of the IRS' provisions and their translation into action, e.g., IRS forms, tables and charts of relevant cases, and comparisons of international transfer pricing rules within particular contexts.  

Table of Contents 

Chapter 1 - Introduction
Chapter 2 - General Principles of Code Sec. 482

• Arm's length standard
• Best method rule
• Comparability
• Arm's length range
• Determination of true taxable income
• Collateral Adjustments
• Transfer pricing and non-recognition provisions
• Blocked income

• Comparable uncontrolled price method (with cases applying this method)
• Resale price method
• Cost plus method
• Cost-plus method
• Comparable profit method
• Profit split method
• Unspecified methods

Chapter 4 - Methods

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Canadian Transfer Pricing describes and clarifies Canada's current transfer pricing rules. It sets out the methods used by the CRA and described in the OECD Guidelines for determination of an arm's length price for goods and services.



Due to the large dollar amounts involved in transfer pricing disputes, the importance of transfer pricing to the Canada Revenue Agency ("CRA") continues to evolve into a prominent component of tax collection and enforcement in Canada. Tax practitioners and company executives need to be aware of the procedures and documentation requirements in order to remain compliant with the transfer pricing rules and to be better prepared in the face of an audit by the CRA. This is also true for companies intending to establish an APA or resolve disputes with the revenue authorities in Canada and overseas with respect to transfer pricing transactions.

Authored by Jules Lewy, BCL, LLB and members of the tax group of one of Canada’s largest and most respected law firms, Dentons, Canadian Transfer Pricing provides a comprehensive overview of the Canadian transfer pricing regime.  This essential edition includes discussion on the OECD’s involvement in the area of transfer pricing tax policy as well as a brief overview of the U.S. transfer pricing legislation.



Chapters Include:

• What is Transfer Pricing?
• Transfer Pricing Rules Prior to 1999
• Canada’s Current Transfer Pricing Rules
• Transfer Pricing and Intra Group Services
• Transfer Pricing and Restructuring
• Contemporaneous Documentation and Transfer Pricing Penalties
• Advance Pricing Agreements
• Transfer Pricing Audit Process
• Transfer Pricing Dispute Resolution
• Competent Authority
• Jurisprudence
• Transfer Pricing and Customs, GST and HST.

If you would like more details about this product, or would like to order a copy online, please click here.

Offers extensive yet clear guidance through the complex maze of U.S. transfer pricing rules. The book is authored by leading experts in the transfer pricing scene. Authors cover all aspects of transfer pricing relevant to the practitioner, starting with general legal principles and apportionment methods, then moving on to more specific subjects such as transfers of tangible vs. intangible goods and the impact of e-commerce and U.S. customs on transfer pricing, and finally exploring highly practical matters like procedural strategies and post-examination procedures. 

• Comprehensive analysis of the U.S. rules, case law and guidance on  transfer pricing for tangible goods, intangibles, and services
• Complex cost-sharing planning principles, including buy-in*
• Cutting edge e-commerce transfer pricing issues
• U.S. penalty and documentation rules
• Documentation with checklists, questionnaires and model report
• U.S. penalty rules compared to those of other important countries
• Overlap between transfer pricing and Customs valuation issues
• Customs ruling based on an APA
• In-depth, step-by-step analysis of the favored approach to transfer pricing controversy, including:
  • Developing a substantive/procedural strategy (with detailed flow-chart)
  • Preparing for examination
  • Identifying post-examination opportunities to resolve the dispute

Special appendices provide a variety of "practice tools" designed to facilitate the understanding of the IRS' provisions and their translation into action, e.g., IRS forms, tables and charts of relevant cases, and comparisons of international transfer pricing rules within particular contexts. 

Table of Contents (Summary)
Chapter 1   Introduction
Chapter 2   General Principles of Code Sec. 482
Chapter 3   Methods for Transfers of Tangible Property
Chapter 4   Methods for Transfer of Intangible Property
Chapter 5   Intercompany Services
Chapter 6   Intercompany Loans and Advances
Chapter 7   Penalties
Chapter 8   The Code Sec. 1059A limitation
Chapter 9   Overall strategy for compliance and controversy
Chapter 10  Preparing transfer pricing documentation
Chapter 11  Examination
Chapter 12  Post-examination procedural alternatives
Chapter 13  Advance pricing agreements
Chapter 14  The OECD approach to transfer pricing
Chapter 15  Customs valuation issues
Chapter 16  State transfer pricing

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Private hospitals say the order in its current form will result in losses and would also affect the salaries of healthcare workers.The reduction in prices for private healthcare providers comes at a time when they are dealing with lower hospital occupancy rates, as patients opt to postpone planned medical procedures due to the pandemic