Publisher's Synopsis
In August 1993 new rules on inter-affiliate pricing, which had been formulated in January of the same year, were made law by the US Congress. The new law determined the correct way of establishing inter-company prices and created severe penalties for companies who failed to comply. These new regulations and the penalties which go with them are extremely important for multinationals in the US and elsewhere. An important new requirement is the obligation to document prices on a contemporous basis rather than after the fact. Another important element is the incorporation of the "commensurate with income" standard of the 1986 Tax Reform Act. Of the existing regulations on inter-company pricing, section 482, which dates from 1968, has undergone significant changes. In the annex are proposed and temporary regulations which should interest companies wishing to anticipate future modifications of today's regulations.;This text consists of 18 chapters divided into the following four parts: overview of the temporary and proposed regulations; structuring and planning transactions involving tangible and intangible property; the new section 6662 penalty rules, documentation requirements, inter-company transaction studies and analyses, advanced pricing agreements and the attorney-client privilege; and practical application of the temporary and proposed regulations.
