IRS finalizes transfer pricing penalty regulations
Article Abstract:
The IRS's final regulations on transfer pricing penalties, issued in Feb 1996, set forth the contemporaneous due diligence requirements and allow taxpayers to propose pricing methods, subject to IRS approval. The due diligence requirements specify pricing methods must be demonstrably reasonable and well-documented. Complying taxpayers may want to secure additional penalty protection by entering into advance pricing agreements with the IRS. The temporary regulations, coordination of penalties, single transaction penalty good-faith exception, and ratable set-off rule are also discussed.
Publication Name: The International Tax Journal
Subject: Business, international
ISSN: 0097-7314
Year: 1996
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International transfer pricing: a Canadian perspective
Article Abstract:
Canadian law on international transfer pricing includes statutory anti-avoidance provisions, case law, Information circular 87-2, and Revenue Canada's Advance Pricing Agreement procedure. Transfer pricing laws cover non-arm's-length transactions between related parties for goods and services, a common practice given Canada's level of international commerce. Although Canadian case law on transfer pricing is inconclusive, the Advance Pricing Agreement appears to be a cost-effective route for companies facing transfer pricing situations.
Publication Name: The International Tax Journal
Subject: Business, international
ISSN: 0097-7314
Year: 1996
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The new protocol to the Canada-United States treaty: a major document
Article Abstract:
The protocol to the tax treaty between the US and Canada signed on Aug 31, 1994, will revise withholding taxes, estate and inheritance taxes, domicile, treaty administration and anti-treaty-shopping provisions. Withholding treatment is revised for dividends, royalties and interest. The US had favorable treaty-shopping provisions included. Double taxation that may have occurred regarding US social security taxes will be creditable. Canadian tax law will recognize a proportion of the US transfer tax unified credit.
Publication Name: The International Tax Journal
Subject: Business, international
ISSN: 0097-7314
Year: 1995
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