This article attempts to summarize existing United States tax law and government policy on arm\u27s-length dealing, with the hope that it will illuminate the current perspective in this important and complex are
When a U.S. person conducts business or investment activity abroad through a foreign corporation in ...
This article compares the U.S. export incentives, the Domestic International Sales Corporation (DISC...
The arm’s-length principle (ALP), the transactions taken place between unrelated parties acting at a...
A revised and updated version of the 1995 article (Va. Tax Review) on the evolution of US transfer p...
In 1988, the US Treasury Department published a study of inter-company pricing (the \u27White Paper\...
Tax policy influences the ability of United States businesses to compete internationally. The 1986 T...
The foundation of international taxable income allocations between related parties is formed by the ...
Using transfer pricing, U.S. Corporations are able to transfer revenues to foreign affiliates with a...
From the publisher: This book addresses the provisions of the Internal Revenue Code that govern the...
Whether a particular set of activities constitute the conduct of a trade or business within the Unit...
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the a...
In this Article, the author analyzes global trading by financial intermediaries of stocks, securitie...
This article will examine the significance of transfer pricing. Further, it will review, as an examp...
The foundation of international taxable income allocations between related parties is formed by the ...
In this Article, Professor Kaufman examines the administrative and jurisdictional functions of the I...
When a U.S. person conducts business or investment activity abroad through a foreign corporation in ...
This article compares the U.S. export incentives, the Domestic International Sales Corporation (DISC...
The arm’s-length principle (ALP), the transactions taken place between unrelated parties acting at a...
A revised and updated version of the 1995 article (Va. Tax Review) on the evolution of US transfer p...
In 1988, the US Treasury Department published a study of inter-company pricing (the \u27White Paper\...
Tax policy influences the ability of United States businesses to compete internationally. The 1986 T...
The foundation of international taxable income allocations between related parties is formed by the ...
Using transfer pricing, U.S. Corporations are able to transfer revenues to foreign affiliates with a...
From the publisher: This book addresses the provisions of the Internal Revenue Code that govern the...
Whether a particular set of activities constitute the conduct of a trade or business within the Unit...
To prevent profit shifting by manipulation of transfer prices, tax authorities typically apply the a...
In this Article, the author analyzes global trading by financial intermediaries of stocks, securitie...
This article will examine the significance of transfer pricing. Further, it will review, as an examp...
The foundation of international taxable income allocations between related parties is formed by the ...
In this Article, Professor Kaufman examines the administrative and jurisdictional functions of the I...
When a U.S. person conducts business or investment activity abroad through a foreign corporation in ...
This article compares the U.S. export incentives, the Domestic International Sales Corporation (DISC...
The arm’s-length principle (ALP), the transactions taken place between unrelated parties acting at a...