International Taxation


Book Description

Covers: whether foreign-controlled companies might have underpaid U.S. income taxes by improperly using transfer pricing; what factors, if any, affected the IRS1 ability to determine and recover any potentially underpaid taxes; and what alternatives to dealing with transfer pricing existed. Charts and tables.




International Taxation


Book Description










A Study of Intercompany Pricing


Book Description

The study is divided into four parts; part I gives the history of Sec. 482 and the evolution of issues leading to the 1986 ammendments, part II discusses Congress' 1986 changes to Sec. 482, part III analyzes economic theories for implementing Sec. 482, amd part III examines cost sharing arrangements.




Uniform Issue List


Book Description




Internal Revenue Bulletin


Book Description




Internal Revenue Cumulative Bulletin


Book Description