Title Taxing Multinationals : Transfer Pricing and Corporate Income Taxation in North America

Published University of Toronto Press 1998

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Description 1 online resource (856 pages) Contents 1. Taxing Multinationals: An Introduction to the Issues -- 2. The International Tax Transfer Pricing Regime -- 3. The Multinational Enterprise as an Integrated Business -- 4. Multinationals and Intrafirm Trade in North America -- 5. The Simple Analytics of Transfer Pricing -- 6. Taxing Multinationals in Theory -- 7. Taxing Multinationals in Practice -- 8. The U.S. Tax Transfer Pricing Regulations Part I: Rules -- 9. The U.S. Tax Transfer Pricing Regulations Part II: Procedures -- 10. The Canadian Tax Transfer Pricing Regulations -- 11. Transfer Pricing and the Tax Courts -- 12. Reforming the Tax Transfer Pricing Regime Part I: Principles and Norms -- 13. Reforming the Tax Transfer Pricing Regime Part II: Rules and Procedures Summary Governments face complex problems in taxing crossborder, intrafirm transactions of multinational enterprises. Such transactions dominate world trade flows and critically affect national tax revenues. However, their values - transfer prices - are set typically inside the multinationals. As a result, governments have established complicated rules based on the arm's length standard to discourage transfer price manipulation. This book draws on the fields of international business, economics, accounting, law, and public policy as they pertain to transfer pricing. It includes a state-of-the-art review of the economic theory of transfer pricing; an international business approach to multinationals and intrafirm trade in North America; complete outlines of the corporate income tax laws and regulations in Canada, the United States, and Mexico as they apply to transfer pricing; a thorough discussion of the roles of the U.S. Treasury and the OECD in developing the arm's length standard; summaries of key transfer pricing court cases; samples of accounting practices and problems; and a critical look at the current tax issues and public policy proposals in regard to taxing multinationals in the twenty-first century. Taxing Multinationals should be of interest to practitioners, researchers, and policy makers who deal with multinational enterprises, international taxation, and intrafirm transactions Subject International business enterprises -- Taxation -- North America Transfer pricing -- Taxation -- North America BUSINESS & ECONOMICS -- International -- Taxation. BUSINESS & ECONOMICS -- Taxation -- Corporate. International business enterprises -- Taxation Transfer pricing -- Taxation Verrechnungspreis Steuerrecht Multinationales Unternehmen Transferprijzen. Vennootschapsbelasting. Internationale ondernemingen. North America Nordamerika Genre/Form e-books. Livres numériques. Form Electronic book ISBN 1282008145 9781282008144

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