Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice


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Global Transfer Pricing Solutions: Li, Jian and Alan Paisey. Palgrave Macmillan. Lowell, Cym H. International Transfer Pricing, 2nd Edition. Markham, Michelle. Transfer Pricing of Intangibles. Mathewson, G. Frank and G. Fiscal transfer pricing in multinational corporations. Ontario Economic Council Research Studies. Toronto : Ontario Economic Council. Murray, Robin, ed. National Industrial Conference Board.

Interdivisional transfer pricing; a research report from the Conference Board. Nieckels, Lars. OECD: Paris. Transfer pricing and multinational enterprises: three taxation issues. Tax aspects of transfer pricing within multinational enterprises : the United States proposed regulations : a report by the Committee on Fiscal Affairs on the proposed regulations under IRC Section Transfer pricing guidelines for multinational enterprises and tax administrations.

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Pagan, Jill C. Scott Wilkie. Transfer Pricing Strategy in a Global Economy. Plasschaert, Sylvain ed. Transnational Corporations, Transfer Pricing, and Taxation. London and New York : Routledge. Plasschaert, Sylvain R. Transfer pricing and multinational corporations: an overview of concepts, mechanisms, and regulations. New York : Praeger Publishers. Rugman, Alan M. Multinationals and Transfer Pricing. Martins Press.

Transfer Pricing and Valuation in Corporate Taxation

Shulman, James S. Transfer Pricing in Multinational Business. Soldiers Field Press, MA. Tang, Roger Y.

Transfer pricing practices in the United States and Japan. Westport , Connecticut : Praeger Publishers. Toronto : Butterworths. Transfer pricing in the s: tax and management perspectives.


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Greenwood Publishing Group. Intrafirm trade and global transfer pricing regulations. Thomas, Arthur Lawrence. Behavioural analysis of joint-cost allocation and transfer pricing. Stipes Publishing Company. Dominant positions of market power of transnational corporations use of the transfer pricing mechanism.

Vaitsos, C. The Bloomberg Tax Estates, Gifts and Trusts Advisory Board is composed of esteemed professionals from renowned corporations, universities, and government entities. He regularly advises domestic and international families and family offices with respect to creating trust and related business structures to preserve, protect, and grow family wealth for multiple generations in a tax efficient manner.

He also advises clients on business succession matters, with a particular emphasis on navigating the various tax pitfalls under Chapter 14 of the Code. Todd also has experience in advising Hedge Fund and Private Equity Fund professionals with respect to transferring carried interests into multi-generational trusts for the benefit of younger family members in a tax-efficient manner.

Heckerling Institute on Estate Planning, where he is a frequent speaker. Steve earned a J. Christine L. Albright concentrates on counseling high-net-worth individuals and family groups in all facets of sophisticated wealth and estate planning and protection, estate, gift and generation-skipping transfer taxation, income taxation of estates and trusts, and succession planning for closely held and family businesses.

She also represents fiduciaries and beneficiaries of trusts and estates regarding all aspects of trust and estate administration, the review and preparation of estate and generation-skipping transfer tax returns, the analysis of fiduciary income tax matters, and trust construction and reformation suits and other contested trust and estate matters. She represents parties in seeking private letter rulings and in handling tax audits for federal estate, gift, generation-skipping transfer and fiduciary income tax matters.

In this role, he is responsible for working with clients and their advisors to develop practical and efficient wealth transfer plans, and for guiding the firm on fiduciary issues. He advised clients, lawyers, and other professionals on estate planning and helped resolve tax issues through IRS appeals and by obtaining rulings from the IRS National Office. He was in the Navy from to , served in the Gulf of Tonkin during the Vietnam War, and achieved the rank of lieutenant.

Marc is a solo practitioner specializing in Trusts and Estates with experience in estate planning, estate and trust administration, and estate and trust litigation. Marc is a frequent author and lecturer. He is a member of a variety of professional organizations holding a variety of positions including as a member of the New York State Bar Association Standing Committee on Legal Education and Admission to the Bar.

Turney P. Berry concentrates his practice in the areas of estate planning, fiduciary matters, and charitable planning. As a Uniform Law Commissioner, Mr. For the American Bar Association, Mr. Since , Mr. He writes and lectures extensively on estate and trust taxation and charitable giving and has authored or co-authored seven books and over articles on estate planning topics.

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He is co-developer of Wealth Transfer Planning, a computerized system that produces estate planning documents using document assembly and specific client advise using artificial intelligence and which is published by Interactive Legal Systems where he serves as editor-in-chief. He is director of estate planning for the Alaska Trust Company.

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Among professional activities, which are too numerous to list, Mr. Jeremy is a partner in the private client and tax team. He counsels families, business owners and successful individuals in all areas of estate planning.

For more than 15 years his practice has focused on sophisticated family wealth and transfer tax planning, complex trust and probate administrations, business succession planning, fiduciary representation, the resolution of Federal estate and gift tax audits, and charitable planned giving. He is a regular speaker and author on sophisticated estate planning and trust administration topics. Richard advises on control, tax, and business planning issues and helps clients save estate taxes and develop succession plans targeted for S corporations, regularly consults with other lawyers, accountants, financial planners, insurance consultants and trust officers on IRS litigation and structuring business transactions.

Has experience on the farm estate tax valuation rules under Code Section A and advises farmers, landowners, and real estate professionals on a variety of tax, leasing and business-planning issues. Richard focuses on estate planning, trusts and estate administration, and beneficiary and fiduciary representation.

He concentrates his practice on complete tax, trusts and estates matters for successful individuals and their families, with a particular emphasis on cross-border matters and the integration of income tax and estate planning goals. Eric also is a frequent writer and lecturer on matters related to tax planning, tax reform, estate planning and trust and estate administration.

Steve is a nationally recognized practitioner in the areas of estate planning and the structuring of privately held businesses. Lawyers, accountants and business owners regularly look to Steve for fresh, highly knowledgeable insights into the best possible tax and estate planning approaches to their transactions.


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  • Steve crafts estate plans for individuals, keeping in mind their financial security and desire to save income and estate tax. In his work for businesses, Steve helps owners plan for the eventual sale to co-owners, employees, or third parties or transfer to family members , and provides a legal framework for an orderly transition while strategically saving income, transfer, and FICA taxes.

    Drawing on his background as an accountant — and his still-current CPA license and Chartered Global Management Accountant credential — Steve structures businesses to achieve business objectives and save income or estate tax. He has helped fledgling businesses organize, thriving businesses restructure to save hundreds of thousands of dollars of income tax when planning a transition to the next ownership group, and mature multi-million or billion-dollar businesses plan tax-saving transfers to the next generation.

    Over the course of his year career, Steve has amassed a deep knowledge of nearly every aspect of tax strategy for privately held businesses and freely shares that knowledge with others in the field. He has represented both groups in comments to the IRS, the U.

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    Treasury, and tax lawmakers. David A. He is one of only 16 U. Handler is a frequent lecturer at professional education seminars. Jerry Hesch is a tax and estate planning consultant for lawyers throughout the country and is Special Senior Tax Counsel hired as a resource for Jeffrey M. An accomplished author, Professor Hesch has published numerous articles, several Tax Management Portfolios, and co-authored a law school casebook on Federal Income Taxation, now in its third edition.

    George D.

    Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice
    Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice
    Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice
    Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice
    Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice
    Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice
    Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice
    Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice Transfer Pricing and Valuation in Corporate Taxation: Federal Legislation vs. Administrative Practice

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