Transfer Pricing Methods: An Applications Guide

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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 Pricing Services
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

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There has never been an easy-to-use and convenient book that addresses salient and fundamental transfer pricing issues . . . until now. Designed to specifically assist mid-sized businesses facing transfer pricing issues now and in the future, Transfer Pricing Methods is a comprehensive guide that provides in-depth coverage of various transfer pricing methods and applications that are available to today's mid-sized corporations. An invaluable reference for all tax managers, CEOs, and CFOs, Transfer Pricing Methods provides a practical focus on the techniques available and their consequences. Featuring contributions from industry experts, complete coverage includes: Comparable profits methods Cost sharing Transactional net-margin method Adjustments of interest rates Resale price techniques Benefiting from the cost-plus method Market share Organisation for Economic Co-operation and Development guidelines Life-cycle analysis Use of multiple-year data

Global Transfer Pricing Solutions Third Edition

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Global Transfer Pricing Solutions Third Edition

Manufacturer: Worldtrade Executive, Inc.
ProductGroup: Book
Binding: Paperback

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Transfer Pricing Methods: An Applications Guide
Transfer Pricing Rules and Compliance Handbook

ASIN: 1893323781

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Reduce your in-country tax exposure when you build a global business strategy that balances your business goals with sound transfer pricing and tax compliance policies. You'll find insight into the major worldwide transfer pricing regimes with in-depth analysis of proactive transfer pricing management, e-commerce, intellectual property, and much, much more. An aggressive market strategy is important to successfully growing a business in any new global market. But, when this strategy doesn't coincide with the often intricate policies of the local tax authorities, profit margins and even the overall business strategy of your company could be at risk. Because that's a risk you can't afford to take, Global Transfer Pricing Solutions walks you through innovative strategies that will help you build an effective transfer pricing policy ... and build your market share as well.

Diplomacy and Displacement: Reconsidering the Turco-Greek Exchange of Populations, 1922-1934

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Diplomacy and Displacement: Reconsidering the Turco-Greek Exchange of Populations, 1922-1934
Onur Yildirim
Manufacturer: Routledge
ProductGroup: Book
Binding: Hardcover

Economic Conditions | Economics | Business & Investing | Subjects | Books

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ASIN: 041597982X

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This study presents a comprehensive, balanced, and factually grounded narrative of the Turco-Greek Exchange of Populations as a historic event that has been the subject of much distortion in the historiographical traditions of nationalist lore in Greece and Turkey, as well as in scholarly publications of various sorts elsewhere over the span of the past eighty years. Diplomacy and Displacement intend to contribute to the general literature on the Exchange by incorporating into the broader picture the Turkish dimension of the event, particularly the Turkish side of the decision-making process, and the episode of the Muslim refugees that have been left outside the scope of the research agenda, thereby, breaking up the established notion of the Exchange skewed towards the Greek side. It thus sheds doubt on the success paradigm attributed to this event. By adopting a people-centered approach to the Lausanne Treaty and its consequences, the book offers a critique of official versions of the story and encourages people to consider policy decisions together with their huge and often devastating implications for the lives of ordinary people.

Average customer rating:

Heightened danger or just hype?

Keys to the Kingdom, The
Jeff Shear
Manufacturer: Doubleday
ProductGroup: Book
Binding: Hardcover

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Technology Transfer | Technology | Science | Subjects | Books

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ASIN: 0385473532
Release Date: 1994-08-01

Customer Reviews:

Heightened danger or just hype?.......2000-07-31

The book covers the intense competition between McDonnell Douglas and General Dynamics to be the prime support company to Japan for their FSX program.

The book is easy to read. It presents an interesting overview of many of the issues impacting releasability of high technology and American competiveness, and the U.S. Government's participation in sensitive areas of international business. For someone with zero exposure to this arena, the book is a good place to start. Keep in mind that the book is written with an agenda in mind and has a very pessimistic view of this process. If you are pro-American/anti-hi tech export, you will love the book. Otherwise, keep a bag of salt near by during your read.

Book Description

The valuation of intangible assets causes tax lawyers and economists a lot of trouble. And when assets cross borders, it gets worse. The (maybe not so-surprising) result is that a considerable number of multinational enterprises use a transfer pricing method to value intangible assets that seems not to comply with regulations of either home or host tax authorities. Although this is a matter of the utmost practical concern, the persistence even growth of the problem clearly raises theoretical issues. This volume considers the valuation of intangible assets from both perspectives, theory and practice, building its practical recommendations on a sound theoretical analysis of the appropriateness of transfer pricing rules for intangible assets as well as on the adequacy of transfer pricing standards and methods for the economic reality of multinational enterprises.

With expert insight into the difficulties inherent in the current regulatory approaches to valuing intangible asset transfers within multinational enterprise networks, the author combines three strands of current concerns, namely:

research into the theory of the multinational enterprise, intangible asset valuation, and international transfer pricing; comparison of transfer pricing policies when intangibles are involved; and the ongoing policy discussions on the subject among international organizations, tax authorities, and taxpayers. The price-setting behavior of multinational enterprises; why intangibles are valuable; the elusiveness of economic fairness standards when every case is different these are among the thought-provoking issues raised in this book. As both a thorough summary of the major ideas and key public policies in its specialized field and a clarifying presentation of recommendations as well as topics and issues for further research, International Transfer Pricing The Valuation of Intangible Assets will greatly benefit international taxation professionals, whether in business, government, or academia.

Customer Reviews:

Good Content, Poor Writing.......2003-10-30

This book brings together a lot of information that I have not found elsewhere in one place.
Be warned, however, that it looks like this book was never carefully proofread by a native english speaker. There are many grammatical errors, the sentence construction is so awkward at times that I had to read some things 2 or 3 times to get a sense of what she is saying and there are even some spelling errors. This was especially irritating because I paid over $100 for the book and expected a higher quality product.

Remittances: Development Impact and Future Prospects

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Remittances: Development Impact and Future Prospects

Manufacturer: World Bank Publications
ProductGroup: Book
Binding: Paperback

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Beyond Small Change: Making Migrant Remittances Count
Lessons from the U.S.-Mexico Remittances Corridor on Shifting from Informal to Formal Transfer Systems (World Bank Working Papers) (World Bank Working Papers)
International Migration, Remittances, and Brain Drain (World Bank Trade and Development Series)
Sending Money Home: Hispanic Remittances and Community Development
Give Us Your Best and Brightest: The Global Hunt for Talent and Its Impact on the Developing World

ASIN: 0821357948
Release Date: 2005-06-06

Product Description

Publication of this book is especially important for my country because our economy depends to a large extent on the remittances of overseas workers. We are particularly interested in the new technologies cited by the authors. These technologies would reduce the cost of remitting money to recipient countries and greatly benefit our workers abroad. Kudos to the World Bank for publishing this comprehensive and useful book. Gloria Macapagal-Arroyo President, Republic of the Philippines Readers will find his book an enthralling reminder of the indissoluble financial links that bind migrants to their home countries. These financial links need to be encouraged and sustained by supportive macroeconomic policies. Tito Mboweni Governor, Reserve Bank of South Africa An excellent examination of the global remittances policy agenda, Remittances: Development Impact and Future Prospects is a timely and exciting resource for academics, development institutions, central banks, and all policy makers in developed and developing countries. Hernando de Soto President, Institute for Liberty and Democracy New research shows the astonishing scope of remittances, with formally documented flows now estimated at $90 billion for 2003. Globally, remittances now constitute the largest source of financial flows to developing countries after Foreign Direct Investment (FDI), and indeed in many countries they now exceed FDI flows. Remittances explores policy options for enhancing the poverty alleviation impact of remittance money in recipient countries, and addressees concerns about increasing migration and inequality. It looks at new technologies that allow remittance service providers to reduce direct transaction costs and open new channels, enhancing convenience for remitters and improving levels of transparency and accountability for regulators and policy makers. Importantly, it also establishes a baseline for further research and collaborative effort, showing the areas where the international financial institutions, particularly the World Bank, can add value to enhance the positive impact of remittance flows and minimize less welcome effects. Edited by Samuel Munzele Maimbo, who has already published authoritative articles on this subject, and Dilip Ratha, who first revealed the global significance of remittances, this book is intended for remittance service providers, as well as policy makers and researchers interested in financial sector, migration and development issues.

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"An excellent examination of the global remittances policy agenda, Remittances: Development Impact and Future Prospects is a timely and exciting resource for academics, development institutions, central banks, and all policy makers in developed and developing countries. Hernando de Soto President, Institute for Liberty and Democracy Re-mit-tance n. 1. The sending of money to someone at a distance. 2. The sum of money sent. New research shows the astonishing scope of remittances, with formally documented flows now estimated at $90 billion for 2003. Globally, remittances now constitute the largest source of financial flows to developing countries after Foreign Direct Investment (FDI), and indeed in many countries they now exceed FDI flows. Remittances explores policy options for enhancing the poverty alleviation impact of remittance money in recipient countries, and addressees concerns about increasing migration and inequality. It looks at new technologies that allow remittance service providers to reduce direct transaction costs and open new channels, enhancing convenience for remitters and improving levels of transparency and accountability for regulators and policy makers. Importantly, it also establishes a baseline for further research and collaborative effort, showing the areas where the international financial institutions, particularly the World Bank, can add value to enhance the positive impact of remittance flows and minimize less welcome effects. Edited by Samuel Munzele Maimbo, who has already published authoritative articles on this subject, and Dilip Ratha, who first revealed the global significance of remittances, this book is intended for remittance service providers, as well as policy makers and researchers interested in financial sector, migration and development issues."

Direct Investment and Joint Ventures in China: A Handbook for Corporate Negotiators

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Intelligence breathes thru the pages
Poor read and not factual.
Prevents joint venture mistakes

Direct Investment and Joint Ventures in China: A Handbook for Corporate Negotiators
James E. Shapiro , Jack N. Behrman , William A. Fischer , and Simon G. Powell
Manufacturer: Quorum Books
ProductGroup: Book
Binding: Hardcover

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Book Description

Written primarily for business managers and government officials, this is a comprehensive and extremely timely handbook on how to successfully initiate and implement joint ventures and direct investments in China. The authors combine in one volume an appreciation of the nuances faced in the negotiation of U.S.-Chinese joint ventures, an examination of the investment environment in China and an assessment of its past traditions, present policies, and emerging problems. Case studies of a variety of actual joint ventures are especially valuable for readers involved in or planning to open negotiations in China. Several chapters assess the impacts of the events in Tianamen Square on foreign direct investment in the country. The book opens with two chapters which examine the reasons for China's open policy and the responses of foreign investors to the new policy. A group of chapters then explores the country's investment, cultural, and legal environments and their likely impacts on joint venture negotiations. Turning to an examination of Chinese markets and production capabilities, the authors assess consumption patterns, decision making, customer/supplier relations, local sourcing problems, transportation, the availability of skilled labor, management, and R&D. They go on to analyze the contributions of foreign direct investment, including the role of transnational corporations, and present a step-by-step guide to negotiating a joint venture in China and implementing the agreement reached. Finally, the authors look at prospects for development and modernization in China, particularly in terms of the trend towards recentralization following the Tianamen Square upheaval. In addition to business development managers, students in international business programs will find Direct Investment and Joint Ventures in China an indispensable resource.

Customer Reviews:

Intelligence breathes thru the pages.......2003-01-09

Shapiro obviously has had years of experience negotiating. He writes clearly and it would be a beneficial book for anyone, students or those already in the field, to read. If I were to teach a course on joint ventures, this would be the text of choice.

Poor read and not factual........1999-02-18

I spent many years living in China and found too many flaws with this book.

Prevents joint venture mistakes.......1997-03-02

Anyone considering negotiating any joint venture would benefit from the checklists and other considerations raised by Shapiro who actually negotiated the showcase Xerox-Shanghai joint venture

India and the Soviet Union: Trade and Technology Transfer (Cambridge Russian, Soviet and Post-Soviet Studies)

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India and the Soviet Union: Trade and Technology Transfer (Cambridge Russian, Soviet and Post-Soviet Studies)
Santosh K. Mehrotra
Manufacturer: Cambridge University Press
ProductGroup: Book
Binding: Hardcover

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ASIN: 0521362024

Book Description

This is the first comprehensive study of trading relations between India and the Soviet Union and the transfer of technology from the latter to the former country. Santosh Mehrotra begins by outlining Indian economic strategy since the 1950s and the place of Soviet and East European technical assistance within this. He considers Soviet economic interests in LDCs in general and India in particular and discusses the special geopolitical relationship between India and the Soviet Union. He goes on to examine Soviet technological transfer to India since 1955 and analyzes legal contracts, markets, labor and managerial skills, technical adaptation and the provision of "follow up" facilities by providing illuminating and detailed case studies of particular industries. In the final chapters, the author considers Indo-Soviet trade in the 1970s and 1980s, covering payment arrangements and bilateral trading and compares the terms of the relationship with India's trade relations with the rest of the world.

Intrafirm Trade and Global Transfer Pricing Regulations

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Dr. Tang: The Authority on Transfer Pricing

Intrafirm Trade and Global Transfer Pricing Regulations
Roger Y. W. Tang
Manufacturer: Quorum Books
ProductGroup: Book
Binding: Hardcover

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ASIN: 1567200397

Book Description

Transfer pricing is the most important issue in international taxation today, but transfer pricing regulations for the United States and its major trading partners have changed significantly over the past decade. Professor Tang explains these changes and their impact on trade among multinational companies. In doing so he covers not only changes in U.S. regulations and their effects on multinational companies, but also the changes that have taken place in Canada, Mexico, China, Japan, the United Kingdom, Germany, France, the OECD, and elsewhere, and their impact on U.S. business. Also discussed in detail are the advance pricing agreements (APA) programs of the United States and Canada; a new paradigm for resolving a variety of issues that have arisen recently in intrafirm trade and transfer pricing; and, for business executives, an approach for managing a corporate transfer pricing system. The book is an essential reading for professionals and their colleagues in the academic community.

Customer Reviews:

Dr. Tang: The Authority on Transfer Pricing.......2000-09-22

With "Intrafirm Trade and Global Transfer Pricing Regulations," Dr. Tang has proven why he remains one of the leading experts of the dynamic environment that is transfer pricing. His comprehensive analysis of development trends in global regulations with relation to local arenas reveals the depth of his vast knowledge, and his more than twenty years of experience in the field. This book is an essential reference for academics specializing in transfer pricing, and a valuable guide for students alike.

Taxing Multinationals: Transfer Pricing and Corporate Income Taxation in North America

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Good introduction to Transferprice Literature

Taxing Multinationals: Transfer Pricing and Corporate Income Taxation in North America
Lorraine Eden
Manufacturer: University of Toronto Press
ProductGroup: Book
Binding: Hardcover

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Transfer Pricing Methods: An Applications Guide

ASIN: 0802007767

Book Description

Governments face complex problems in taxing crossborder, intrafirm transactions of multinational enterprises. Such transactions dominate world trade flows and critically affect national tax revenues. However, their values - transfer prices - are set typically inside the multinationals. As a result, governments have established complicated rules based on the arm's length standard to discourage transfer price manipulation.

This book draws on the fields of international business, economics, accounting, law, and public policy as they pertain to transfer pricing. It includes a state-of-the-art review of the economic theory of transfer pricing; an international business approach to multinationals and intrafirm trade in North America; complete outlines of the corporate income tax laws and regulations in Canada, the United States, and Mexico as they apply to transfer pricing; a thorough discussion of the roles of the U.S. Treasury and the OECD in developing the arm's length standard; summaries of key transfer pricing court cases; samples of accounting practices and problems; and a critical look at the current tax issues and public policy proposals in regard to taxing multinationals in the twenty-first century.

Taxing Multinationals should be of interest to practitioners, researchers, and policy makers who deal with multinational enterprises, international taxation, and intrafirm transactions.

Customer Reviews:

Good introduction to Transferprice Literature.......2002-04-05

Perhaps the best (introduction) book on transferprices and multinationals I've ever read. Eden provides a good introduction in the economic theory of multinationals founded on the theory of the firm. Afterwards, she presents the microeconomic basis of the effects of taxation on the production process within the MNE. Propositions for a future taxation system in the EU are made, also the unitary concept is evaluated.

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