International Taxation: Introduction to U.S. Transfer Pricing, Part I

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Wyoming CLE
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About This Course

US Transfer Pricing has long history in the US both from the regulatory and statutory perspectives. This CLE course will explore this history as well as the overall concepts that guide the US transfer pricing between the IRS and taxpayers and the IRS and government with whom we maintain tax treaties. The course will include explanations of the various concepts including the arm’s length standard, control, best method rule, formulary apportionment, comparability and reliability. The course will also cover regulatory methods to price controlled transactions involving tangible properties.

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