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Transfer Pricing Fundamentals  

CATEGORY: Taxation
COURSE ID: CLTRAN, VERSION 6.00
(63)
Online & Mobile, Download
8 CPE Credits
Level: Advanced

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. 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.

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