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Transfer Pricing Methods »

Book cover image of Transfer Pricing Methods by Feinschrei

Authors: Feinschrei, Feinschreiber
ISBN-13: 9780471573609, ISBN-10: 0471573604
Format: Hardcover
Publisher: Wiley, John & Sons, Incorporated
Date Published: February 2004
Edition: (Non-applicable)

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Author Biography: Feinschrei

ROBERT FEINSCHREIBER is a practicing attorney and counselor, as well as a former CPA. As a partner in the firm of Feinschreiber & Associates, his clients include foreign-owned U.S. businesses, U.S. exporters, and companies facing international tax issues. He has written and edited many books, including the Transfer Pricing Handbook, Third Edition, Export Handbook, and International Mergers and Acquisitions, all published by Wiley.

Book Synopsis

Advanced praise for Transfer Pricing Methods
"Feinschreiber and a team of renowned executives have provided the definitive transfer-pricing guide to this challenging area. At a time when many companies are reviewing documents, policies, and procedures, it's wonderful to have a concise, clearly written reference focused on what may be the most critical corporate tax issue."
-Charles R. Goulding, Managing Director, Tax
Cooper Industries, Inc.
"It is refreshing to find a treatise on transfer pricing that combines practical business considerations, economic theory, and a discussion of technical tax rules in a way that is meaningful not only for large corporate enterprises but also small and medium-sized businesses."
-Vikram A. Gosain, JD, CPA, Director of Transfer Pricing
General Electric Capital Corporation
"This well-written book will be useful both to attorneys new to the practice area and to older hands. It includes very helpful discussions on valuation issues that will be particularly useful for in-house counsel and accountants."
-Joseph C. Mandarino, Partner
Troutman Sanders, LLP
"Feinschreiber and his contributors have cogently explained hundreds of useful facets in the transfer pricing field that have taken others volumes to articulate. The busy professional should consider this book in his or her quest for knowledge in the scintillating tax specialty."
-Charles L. Crowley, Partner
ITS/Customs and International Trade Practice, Ernst & Young, LLP
"Transfer Pricing Methods . . . should become a standard tool for every owner-managed and mid-cap multinational."
-Enrique MacGregor, Principal-in-Charge, Transfer PricingServices
Grant Thornton LLP
"Bob's vast experience in transfer pricing matters has again been captured between the covers of a book. Thank you, Bob, and your contributing colleagues, for producing another valuable helpmate."
-Alan Getz, Vice President and General Manager, Tax
Mitsui & Co., Inc. (U.S.A.)
"Feinschreiber's current publication is a practical handbook that presents transfer pricing tools that can assist tax professionals of mid-sized companies to optimize profits, manage cash flows, and moderate taxes in a defensible manner."
-Per H. Hasenwinkle, National Practice Leader, Transfer Pricing
BDO Seidman, LLP

Table of Contents

Preface
Pt. 1Understanding Transfer Pricing1
Ch. 1Practical Aspects of Transfer Pricing3
Ch. 2Business Facets of Transfer Pricing13
Ch. 3General Principles and Guidelines40
Ch. 4Transfer Pricing Basics49
Pt. 2Applying Specific Transfer Pricing Techniques61
Ch. 5Comparable Uncontrolled Price Method, Resale Price Method, and Cost-Plus Method63
Ch. 6Comparable Profits Method84
Ch. 7Comparable Uncontrolled Transaction Method for Intangibles93
Ch. 8Transfer Pricing for Services138
Ch. 9Cost Sharing163
Ch. 10Profit Methods191
Pt. 3Focus on International Transfer Pricing Issues197
Ch. 11Foreign-Owned U.S. Corporations Reporting199
Ch. 12Organization for Economic Cooperation and Development Guidelines206
Ch. 13Transactional Net Margin Method226
Pt. 4Avoiding Transfer Pricing Penalties243
Ch. 14Transfer Pricing Penalties245
Ch. 15Transfer Pricing Penalty Exclusion for Contemporaneous Documentation263
Pt. 5Advanced Transfer Pricing Issues277
Ch. 16Advanced Transfer Pricing279
Ch. 17Unfolding Transfer Pricing Issues292
Index313

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