By Elizabeth King
This e-book analyzes the disparities either among federal statutes and rules, and laws and administrative practices, in hugely debatable parts of company tax coverage: intra-company move pricing and intangible asset valuations. It addresses matters which may suggest thousands of thousands of bucks to person firms, and an important fraction of the federal government's profit base. Tax practitioners and specialists who're understandably annoyed in their efforts to divine the IRS's reasoning in move pricing and valuation matters will locate the publication very priceless. it is going to additionally locate an viewers between elected representatives, different public officers, and tax lobbyists within the technique of comparing present company tax coverage or formulating replacement tax regulations. moreover, the ebook is an invaluable reference for teachers learning foreign taxation, public finance, and treaty compliance.
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Extra info for Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice
The safe harbor applies only if the creditor entity is not in the trade or business of making loans or advances. 30 In this event‚ all relevant factors are to be considered‚ including the amount and duration of the loan‚ the borrower’s creditworthiness‚ the riskiness of the particular project to which the loan or advance will be applied‚ etc. 31 Enforcement and Compliance From the outset‚ the 1968 regulations proved very difficult to apply‚ principally because closely comparable uncontrolled transactions or firms were generally extremely hard to come by.
37 Congress also proposed that these benefits be measured by profits‚ although the White Paper retreated from this position somewhat. 26 Chapter 2: Transfer Pricing and Valuation Regulations on January 24‚ 1992‚ and the third incorporated into the now-extant 1993 temporary regulations. These initiatives all contain specific adjustment methodologies to be applied when intangible property is transferred within a controlled group. All of them incorporate the periodic adjustment requirement discussed in the Committee Report to the 1986 Act (but ultimately omitted from the statutory changes).
Memor. 1992-561‚ 9/23/92‚ for example. 35 See‚ for example‚ Bausch & Lomb‚ Supra‚ and The R. T. French Company v. C. 836 (1973). Chapter 2: Transfer Pricing and Valuation Regulations 24 contrast‚ the IRS has sometimes taken the view that companies are able to predict the success of new products embodying the licensed intangibles (or the cost savings attributable thereto) more accurately than their projections might suggest‚ that projections can easily be manipulated to justify a desired intra-company royalty cross-charge‚ and that actual rather than projected results should therefore determine compensation on an ongoing basis.