Taxing Multinationals: Transfer Pricing and Corporate Income Taxation in North America

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University of Toronto Press, 1998 - Business & Economics - 757 pages
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Governments face complex problems in taxing crossborder, intrafirm transactions of multinational enterprises. Such transactions dominate world trade flows and critically affect national tax revenues. However, their values - transfer prices - are set typically inside the multinationals. As a result, governments have established complicated rules based on the arm's length standard to discourage transfer price manipulation.

This book draws on the fields of international business, economics, accounting, law, and public policy as they pertain to transfer pricing. It includes a state-of-the-art review of the economic theory of transfer pricing; an international business approach to multinationals and intrafirm trade in North America; complete outlines of the corporate income tax laws and regulations in Canada, the United States, and Mexico as they apply to transfer pricing; a thorough discussion of the roles of the U.S. Treasury and the OECD in developing the arm's length standard; summaries of key transfer pricing court cases; samples of accounting practices and problems; and a critical look at the current tax issues and public policy proposals in regard to taxing multinationals in the twenty-first century.

Taxing Multinationals should be of interest to practitioners, researchers, and policy makers who deal with multinational enterprises, international taxation, and intrafirm transactions.

  

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Amazing book. Very informative and educative. A must for every transfer pricing specialist.

Contents

An Introduction to the Issues
3
MULTINATIONALS AND INTRAFIRM TRADE
11
The International Tax Transfer Pricing Regime
63
The Multinational Enterprise as an Integrated Business
125
Multinationals and Intrafirm Trade in North America
174
The Simple Analytics of Transfer Pricing
211
Taxing Multinationals in Theory
279
The U S Tax Transfer Pricing Regulations
383
Transfer Pricing and the Tax Courts
525
Reforming the Tax Transfer Pricing Regime
549
Reforming the Tax Transfer Pricing Regime
584
Conclusions and Policy Recommendations
634
Notes
653
Glossary
697
Bibliography
705
Author Index
737

The U S Tax Transfer Pricing Regulations
454
The Canadian Tax Transfer Pricing Regulations
483

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About the author (1998)

LORRAINE EDEN is Associate Professor, Department of Management, Texas A&M University. She is general editor of Multinationals in North America.

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