scholarly journals Causal-Comparative Macroeconomic Behavioral Study: International Corporate Financial Transfer Pricing in the United States

2021 ◽  
Author(s):  
Karina Kasztelnik
Keyword(s):  
United States ◽  
Transfer Pricing ◽  
The United States ◽  
Behavioral Study ◽  
Causal Comparative ◽  
Financial Transfer

Taxes, Transfer Pricing, and The Multinational Enterprise

2009 ◽  
Author(s):  
Lorraine Eden
Keyword(s):  
United States ◽  
Multinational Enterprises ◽  
Transfer Pricing ◽  
Multinational Enterprise ◽  
The United States ◽  
International Taxation ◽  
Complex Issue ◽  
Daunting Task ◽  
National Governments

For more than ten years now, transfer pricing has been the top international taxation issue faced by multinational enterprises (MNEs). This article aims to outline, for the reader, the complex issue of transfer pricing, as seen by MNE managers and by governments faced with the daunting task of taxing business profits. The article is organized as follows. First, it briefly discusses transfer pricing from the MNE's perspective and the problems that this raises for national governments. It then reviews the basic rules of international taxation as they apply to MNE profits. The specific rules and procedures that apply to transfer pricing, as practiced in the United States and recommended by the OECD, are then outlined. It concludes with a discussion of unresolved problems that are likely to plague transfer pricing over the next few years.

scholarly journals Income Tax Complexity Faced by Multinational Corporations: A Comparative Study of Canada, the United States, and Other Selected OECD Countries

2021 ◽  
Vol 69 (3) ◽  
pp. 745-790
Author(s):  
Susann Sturm
Keyword(s):  
United States ◽  
Multinational Corporations ◽  
Income Tax ◽  
Transfer Pricing ◽  
The United States ◽  
Oecd Countries ◽  
The Us ◽  
Tax Complexity ◽  
Medium Level ◽  
Foreign Corporations

This study examines the complexity of Canada's corporate income tax system from the perspective of multinational corporations and compares it with the complexity of the US system, also taking into account measures of complexity for 19 other member countries of the Organisation for Economic Co-operation and Development (OECD). The author finds that with regard to the Canadian tax code, the most complex laws are those on corporate reorganization, transfer pricing, and controlled foreign corporations, and with regard to the Canadian tax framework, the most complex areas are tax audits, tax-law enactment, and tax guidance. In comparison with other OECD countries, Canada is remarkably similar to the United States. Both countries have a medium level of overall complexity, and both have a more complex tax code but a less complex tax framework than other countries. However, a closer examination of the Canadian and US tax codes and tax frameworks reveals some significant differences in complexity levels, particularly in respect of certain tax laws.

QUANTITATIVE BEHAVIORAL STUDY OF BOTTLENOSE DOLPHINS IN SWIM-WITH-DOLPHIN PROGRAMS IN THE UNITED STATES

1995 ◽  
Vol 11 (4) ◽  
pp. 520-544 ◽  
Author(s):  
AMY Samuels ◽  
Trevor R. Spradlin
Keyword(s):  
United States ◽  
Bottlenose Dolphins ◽  
The United States ◽  
Behavioral Study

scholarly journals Transfer pricing disputes in the United States

2014 ◽  
pp. 27-94
Author(s):  
Reuven S. Avi-yonah
Keyword(s):  
United States ◽  
Transfer Pricing ◽  
The United States

scholarly journals Amazon Inc., BEPS, and the New Method of Risk Allocation: Comparing U.S. Jurisprudence and OECD Approaches to Risk Allocation in the Post-BEPS Era of Transfer Pricing

2017 ◽  
Author(s):  
Charles Edward Andrew Lincoln
Keyword(s):  
United States ◽  
International Law ◽  
Transfer Pricing ◽  
The United States ◽  
Secondary Source ◽  
Risk Allocation ◽  
Tax Reforms ◽  
Stare Decisis ◽  
Secondary Sources ◽  
Tax Court

Will the United States Tax Court apply Action 9’s recommendations regarding risk allocation for transfer pricing purposes?In short, no.The U.S. Tax Court will not apply the OECD BEPS Action 9 Recommendation regarding risk allocation for three reasons. (1) Two Constitutional reasons: (a) the Constitutional cavalcade of hierarchy regarding international law in the United States—much less the precedential value of a secondary source, such as OECD reports. (b) The concept of stare decisis that is embedded in the common law system of the Anglo-American tradition relies on cases being decided as they have been decided in the past. The tradition of upholding prior precedent is not easily broken—except for egregious reasons, such as regarding slavery. (2) Given the status of international law and international secondary sources in the United States in addition to the concept of stare decisis, the U.S. Tax Court—as all courts in the United States—consistently build on judicial application of law. Four key transfer pricing cases since the 1986 transfer pricing tax reforms in the United States will be shown to support the concept of stare decisis.(3) Finally, the most recent transfer pricing case—Amazon—shows that the Court still upholds the prior precedential cases through stare decisis. Moreover—and perhaps more importantly in the international context regarding other countries’ decision to implement Action 9—had the IRS brought the argument of Action 9 forward, not only would the entire case would have been analyzed differently, but the prospect of bringing Action 9’s reasoning forward, the IRS would have for forfeited all claims to the pricing of the transferred intellectual property (IP) to the “empty company”—as will be shown later.

A behavioral study of international technology transfer between the United States and West Germany

1973 ◽  
Vol 2 (3) ◽  
pp. 160-184 ◽  
Author(s):  
B.M. Köhler ◽  
A.H. Rubenstein ◽  
C.F. Douds
Keyword(s):  
United States ◽  
Technology Transfer ◽  
The United States ◽  
West Germany ◽  
Behavioral Study ◽  
International Technology Transfer

Canada and the United States—Trading Partners and Transfer Pricing Opponents?

2017 ◽  
Vol 47 (3) ◽  
pp. 249-265
Author(s):  
Susan C. Borkowski ◽  
Mary Anne Gaffney
Keyword(s):  
United States ◽  
Transfer Pricing ◽  
The United States ◽  
Trading Partners

Party Strength in the United States: Some Corrections

1975 ◽  
Vol 37 (2) ◽  
pp. 641-642 ◽  
Author(s):  
Paul T. David
Keyword(s):  
United States ◽  
The United States ◽  
Party Strength
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