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Unraveling the Conundrum that is Transfer Pricing

February 22, 2022

With the continuing economic effects of the coronavirus (COVID-19) pandemic and ever-growing government deficits, the United States and other jurisdictions have increasingly looked to transfer pricing adjustments to account for lost revenue. If you are a practitioner or an economist working with a multinational entity, there has never been a better time to grasp the transfer pricing rules.

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    Discover how the purpose of the transfer pricing rules, found under I.R.C. Section 482 and its regulations, is to prevent "commonly controlled" taxpayers from artificially shifting taxable income from the U.S. to lower or no-tax jurisdictions. The rules apply to (1) sales of products between countries and entities, (2) sales of businesses, (3) intercompany service relationships, (4) leases and licenses, and (5) outbound and inbound transfers of intangible property.
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