International Transfer Pricing

A study of the intercompany pricing issues that confront taxpayers doing business in multiple jurisdictions. The course will examine the regulations under Section 482 of the Internal Revenue Code that govern the pricing of goods, services and intangibles among commonly controlled entities. It will cover a number of significant cases litigated under Section 482 and the practical problems that confront the IRS, the courts, and taxpayers in those cases, such as determining whether common control exists and whether comparable transactions can be found. The course will also examine potential transfer pricing penalties that might be imposed under Section 6662 and the documentation necessary to avoid those penalties.

Course Information
Course #: LAW 721
Program: LLM
Area of Study: Tax and Estate Planning
Credit Hours: Two credit hours.