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.In its stead, we developed an alternative valuation based on the replacement cost approach, using data that V had ... The differential between income-based and replacement cost valuations in this case also lent credence to our view that V anbsp;...
|Title||:||Transfer Pricing and Valuation in Corporate Taxation|
|Publisher||:||Springer Science & Business Media - 1994|