International transfer pricing: application and analysis.

Ohio CPA Journal, The, August, 1995 by McBride, Jennifer L.; Sherman, W. Richard

In 1994, the IRS issued its final regulations under Section 482. These regulations change the position which the Service had previously taken concerning acceptable transfer-pricing methods. This article examines the new rules and illustrates their application in an international case setting. (Reprinted by permission of the publisher.)

Last year, the final regulations governing acceptable transfer-pricing methodologies (TPMs) were issued by the IRS. Applicable to tax years beginning after October 6, 1994 (and to all open tax years as well), these regulations represent a shift in the approach which the IRS has taken in the past in its examination of the transfer-pricing policies and methodologies which a company employs. Consequently, it is important to understand the...

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