Part of the Premier International Tax Library
Tax Management Portfolio, Transfer Pricing: The Code, the Regulations, and Selected Case Law, is the foundation of the Transfer Pricing Portfolio Series.
Price: $400 Print
This Portfolio is part of the Premier International Tax Library, a comprehensive resource including nearly 100 international tax Portfolios, practice tools, primary sources and timely news.FREE TRIAL
A. Background Facts
B. USS Operations
II. Tax Disputes
A. 1988-1989 Taxable Years
1. IRS Audit of 1988 and 1989 Taxable Years
a. Initiation of Audit
b. IRS Document Request
c. Proposed IRS Adjustments
d. USS Options After Audit
2. IRS Appeals Office Consideration of 1988 and 1989 Taxable Years
b. Appeals Office Response
c. USS Counterproposal
3. Competent Authority Consideration of 1988-89 Taxable Years
B. 1990-1991 Taxable Years
1. 1990-1991 Audit
a. IRS Document Requests
b. Proposed IRS Adjustments
c. Options Available to USS
2. IRS Appeals Office Consideration of 1990-91 Taxable Years
a. Taxpayer Protest
b. Appeals Office Conference
c. Taxpayer Counterproposal
d. Terms of the Settlement
3. Competent Authority Consideration of 1990-91 Taxable Years
C. 1992-1994 Taxable Years
1. Reported Results
2. Audit of 1992-1994 Taxable Years
3. Appeals Office Consideration of 1992-1994 Taxable Years
a. D'Andrea Study of Comparable Distributors
(1) Functional Analysis
(2) Arm's Length Range
(3) Use of Multiple Year Data
(4) Selection of Best Method
(5) Comparability Adjustments
(6) Results of the Study
b. Appeals Office Response
4. Competent Authority Resolution of 1994 Adjustment
D. 1995 and Beyond
1. Consideration of Advance Pricing Agreement
2. Consideration of Cost Sharing Agreement
Table of Worksheets
Worksheet 1 Consumer Products Comparability Analysis of Financial Results Three Year Average of 1992-1994
Worksheet 2 Consumer Products Comparability Analysis of Financial Results for 1994
Worksheet 11 IRC Section 482
Worksheet 12 1994 Final Section 482 Regulations.
Worksheet 13 1993 Temporary and Proposed Section 482 Regulations.
Worksheet 14 1968 Section 482 Regulations.
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