- NY Credits : 8.0
- TX Credits : 8.0
- IRS Enrolled Agent Credits : Federal Tax/Tax Related Matters - 8.0
Transfer Pricing Fundamentals
In today's supply chains, borders are constantly being crossed with respect to the sales of goods and the provision of services. No company no matter how big or how small is immune to engaging in cross border transactions. Whether it is a domestic manufacturer, wholesaler, retailer, or service provider, somewhere in its business a cross border transactions can be found.
Where the cross border transaction is with a related party, arms-length transfer pricing principles will apply to determine the profit allocation to the jurisdictions where the transactions are deemed to occur.
This course has been updated with the impact of the Tax Cuts and Jobs Act.
This course focuses on the development of in-depth knowledge, skill and application of transfer pricing. This course is most appropriate for the professional with mastery of transfer pricing who may be a seasoned professional within an organization but also may be appropriate for other professionals with certain specialized knowledge in taxation.
In the U.S., this can occur domestically within interstate commerce between the states, or internationally, between the U.S. and foreign countries. This course will focus on the U.S. transfer pricing rules found principally under the Section 482 income tax regulations including two of the more important transfer pricing developments T.D. 9738 and T.D. 9773.
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.