Description
One of the most important issues in the taxation profession today is transfer pricing because it is on the books of most countries around the world and has grown internationally. Transfer pricing is not limited to international transactions. Transfer pricing can apply where there are two taxpayers in the same country with different tax regimes; where there are sub-national governments with business spanning across the political boundaries; or where business crosses international borders. To enforce transfer pricing legislation, governments have instituted documentation requirements along with penalties for violations. There are different models of transfer pricing in place today. This course focuses on the U.S. transfer pricing rules found principally under the Section 482 income tax regulations, updated for the impact of the Tax Cuts and Jobs Act, and focuses on the development of in-depth knowledge, skill, and application of transfer pricing.
Learning Objectives
Upon successful completion of this course, the user should be able to:
-recognize the tax policy behind arms-length standard;
-compare and select the best transfer pricing method for the circumstances;
-identify how to apply comparability standards within a transfer pricing project;
-determine how to apply the arms-length range;
-recognize the methods to determine related party transfer pricing profit allocations with respect to sales, services, licenses, leases, and lending;
-determine the particulars related to implications of cost sharing; and
-identify transfer pricing documentation requirements.