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

King, Elizabeth

Hardcover

ISBN 10: 0792393929 ISBN 13: 9780792393924

Verlag: Springer, 1993

Inhaltsangabe

Book by King Elizabeth

Über diesen Titel

Reseña del editor:

Transfer Pricing and Valuation in Corporate Taxation analyzes the disparities between both federal statutes and regulations, and r- ulations and administrative practice, in a highly controversial area of corporate tax policy: intra-company transfer pricing for tax p- poses. It addresses issues that often mean millions of dollars to in- vidual corporations, and a significant fraction of the federal gove- ment’s revenue base. These disparities between law, regulations, and administrative practice are concerning on a number of grounds. First, they - pose considerable economic costs by inducing corporations to engage in a variety of “rent-seeking” activities designed to reduce their - pected tax liabilities, and by requiring the IRS to devote still more to enforcement efforts that are very often futile. Second, they are in- ; herently undemocratic. Administrative practice is currently ad hoc by relying on dispute resolution procedures that can and do yield very different settlements on disputed tax issues from one case to another, the IRS often ends up treating similarly situated cor- rations very differently. Moreover, to the extent that the disp- ity between statute and implementation reflects the IRS’s failure to carry out Congress’ will, the laws passed by duly elected officials are effectively being superseded by administrative procedure, developed incrementally by individuals who are not answerable to an electorate.

Reseña del editor:

This book analyzes the disparities both between federal statutes and regulations, and regulations and administrative practices, in two highly controversial areas of corporate tax policy: intra-company transfer pricing and intangible asset valuations. It addresses issues that can mean hundreds of millions of dollars to individual corporations, and a significant fraction of the federal government's revenue base.
Tax practitioners and consultants who are understandably frustrated in their efforts to divine the IRS's reasoning in transfer pricing and valuation issues will find the book very useful. It will also find an audience among elected representatives, other public officials, and tax lobbyists in the process of evaluating existing corporate tax policy or formulating alternative tax policies. In addition, the book is a useful reference for academics studying international taxation, public finance, and treaty compliance.

Über diese Auflage

• Verlag: Springer
• Erscheinungsdatum: 1993
• ISBN 10: 0792393929
• ISBN 13: 9780792393924
• Einband: Tapa dura
• Anzahl der Seiten: 308