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Transfer Pricing and Valuation in Corporate Taxation - Federal Legislation vs. Administrative Practice (Hardcover, 1994 ed.)
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Transfer Pricing and Valuation in Corporate Taxation - Federal Legislation vs. Administrative Practice (Hardcover, 1994 ed.)
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Transfer Pricing and Valuation in Corporate Taxation analyzes the
disparities between both federal statutes and regulations, and r-
ulations and administrative practice, in a highly controversial
area of corporate tax policy: intra-company transfer pricing for
tax p- poses. It addresses issues that often mean millions of
dollars to in- vidual corporations, and a significant fraction of
the federal gove- ment's revenue base. These disparities between
law, regulations, and administrative practice are concerning on a
number of grounds. First, they - pose considerable economic costs
by inducing corporations to engage in a variety of "rent-seeking"
activities designed to reduce their - pected tax liabilities, and
by requiring the IRS to devote still more to enforcement efforts
that are very often futile. Second, they are in- ; herently
undemocratic. Administrative practice is currently ad hoc by
relying on dispute resolution procedures that can and do yield very
different settlements on disputed tax issues from one case to
another, the IRS often ends up treating similarly situated cor-
rations very differently. Moreover, to the extent that the disp-
ity between statute and implementation reflects the IRS's failure
to carry out Congress' will, the laws passed by duly elected
officials are effectively being superseded by administrative
procedure, developed incrementally by individuals who are not
answerable to an electorate.
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