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Lewis Library - ML3197.C68 2019

In a major shake-up amidst the rising coronavirus cases in Mumbai, BMC Commissioner Praveen Pardeshi has been shunted out. He is transferred as an ad

Dewey Library - HG1601.T355 2018

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Simple pieces of equipment decrease the danger of moving small volumes of chemicals prone to igniting

Las piezas reducen de forma sencilla el peligro al transferir pequeños volúmenes de productos químicos inflamables

Simple pieces of equipment decrease the danger of moving small volumes of chemicals prone to igniting

Individuals moving between Canada and the United States face a daunting array of Canadian and U.S. tax issues, particularly when the move is due to an employment-related transfer. This book provides an overview of key taxation principles related to employment both in Canada and in the United States, and highlights the interaction between the tax laws of these two countries. For employers, this book offers practical guidance on tax issues for the purpose of managing expatriate costs, designing an effective cross-border employee relocation program and retaining key employees.

Key Topics include:

• Overview of the Canadian and U.S. personal tax systems
• Tax reimbursement programs, including sample tax equalization calculations
• Foreign tax credits and tax relief available under the Canada-U.S. tax treaty
• The implications of changes under the fifth protocol to the Canada-U.S. treaty which entered into force on December 15, 2008
• Investments in partnerships, limited liability companies, and other entities
• Taxation of artists and athletes
• Estate planning, including U.S. estate tax issues
• Executive compensation, including various types of equity compensation and long-term incentive plans available
• Expanded discussion on the U.S. deferred compensation rules 

About the Author

Benita Loughlin, CA, is a Partner in the International Executive Services practice at KPMG LLP in Vancouver, B.C. She specializes in tax planning and compliance for individuals, estates and trusts in a U.S. and cross-border context. She advises executives and their employers on tax matters related to compensation, investments, retirement plans, estate planning, and expatriation, with emphasis on employees relocating to or from other countries. The book includes contributions from KPMG International Executive Services professionals in Vancouver who specialize in helping clients manage complex personal tax issues in a cross-border environment. KPMG’s multinational corporate clients face challenges managing tax issues that affect their global workforce. Executives and employees rely on KPMG’s international tax planning to help manage their tax liabilities and maintain their global workforce.

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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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It's often a very difficult decision for your client to make, when they must decide whether to transfer holdings in their farm or farm property. But the complexity doesn't end there. While that decision is being made, the advisors must step in and help to ensure that the transactions are arranged in the most tax efficient and practical manner. For those approaching any potential farm restructurings or sales, this webinar will be essential.

This archive webinar covers a comprehensive look at the preferential tax treatment that transfers of qualifying farms or farm property can enjoy on passing to the next generation or on the sale to outside parties. This includes an overview of the capital gains exemption available for the sale of qualifying farm property shares and partnership interests, and rollovers to certain family members (both inter vivos and on death). While similarities do exist with among these transfers, there are traps and nuances that practitioners must be aware of to ensure their transactions qualify for beneficial tax treatment desired.

More specifically, for each of the above types of transfers, this archived webinar will explore:

• What property qualifies for the treatment?
• Who is entitled to the preferential tax benefit?
• What does farming mean in these contexts?
  • What is the business of farming for tax purposes?
  • What is being "actively engaged on a regular and continuous basis"?
  • Who must farm the property?
  • When must farming activity take place?
  • How much of the property must be used in farming?
• What are the common things farms may do to fall offside?
• Putting it all together - a compare & contrast with examples
• Bonus Issue (time permitting) - Craig vs. the Queen - restricted farm losses

Note: This webinar took place on October 1, 2013.

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