Taxing Multinationals : : Transfer Pricing and Corporate Income Taxation in North America / / Lorraine Eden.

• Superior document: Title is part of eBook package: De Gruyter University of Toronto Press eBook-Package Archive 1933-1999
• VerfasserIn: Eden, Lorraine,
• Place / Publishing House: Toronto : : University of Toronto Press, , [2017]; ©1998
• Year of Publication: 2017
• Language: English
• Physical Description: 1 online resource (856 p.)

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.

Table of Contents

Frontmatter -- Contents -- Preface -- Part I. The Rules of the Game -- 1. Taxing Multinationals: An Introduction to the Issues -- 2. The International Tax Transfer Pricing Regime -- Part II. Multinationals and Intrafirm Trade -- 3. The Multinational Enterprise as an Integrated Business -- 4. Multinationals and Intrafirm Trade in North America -- Part III. Transfer Pricing and Taxation -- 5. The Simple Analytics of Transfer Pricing -- 6. Taxing Multinationals in Theory -- 7. Taxing Multinationals in Practice -- Part IV. The Rules of the Game in North America -- 8. The U.S. Tax Transfer Pricing Regulations. Part I: Rules -- 9. The U.S. Tax Transfer Pricing Regulations. Part II: Procedures -- 10. The Canadian Tax Transfer Pricing Regulations -- 11. Transfer Pricing and the Tax Courts -- Part V. Reforming the Rules of the Game -- 12. Reforming the International Tax Transfer Pricing Regime. Part I: Principles and Norms -- 13. Reforming the Tax Transfer Pricing Regime. Part II: Rules and Procedures -- 14. Conclusions and Policy Recommendations -- Notes -- Glossary of Economic and Accounting Terms -- Bibliography -- Author Index -- Subject Index