William Byrnes' Tax, Wealth, and Risk Intelligence

William Byrnes (Texas A&M) tax & compliance articles

What’s New in the 4th Edition Practical Guide to U.S. Transfer Pricing?

Posted by William Byrnes on December 20, 2019


Highlights

In this release, Professor William Byrnes launches a new 4th Edition of Practical Guide to U.S. Transfer Pricing, in which chapters have been reorganized, substantially revised and expanded to align the publication to the Tax Cuts and Jobs Act, the 2017 OECD Transfer Guidelines and BEPS, and the 2017 UN Practical Manual.

His new edition has 47 chapters, 1,800 pages of technical, jurisprudence, and regulatory analysis to advise clients from a tax risk management perspective and to mitigate controversy. Order a copy here: https://store.lexisnexis.com/products/practical-guide-to-us-transfer-pricing-skuusSku60720

There are 29 U.S. specific chapters (Part I), 7 OECD/BEPS/EU chapters (Part II, IV), 9 industry-specific chapters (Part V), 2 foreign country chapters (Part VI).

New Country Chapters. India (Chapter 121) and Brazil (Chapter 120).

Financial Industry Chapters. Financial Industry Transfer Pricing Issues (Chapter 92), Determining Arm’s Length Interest (Chapter 93), Defending Intercompany Debt (Chapter 94), Performance Guarantees (Chapter 95).

Business Structuring Chapters. Business Restructuring: U.S. Tax and Transfer Pricing Rules (Chapter 27), Mergers and Acquisitions (Chapter 96), International Strategy for Transfer Pricing Compliance: A Checklist for Multinationals (Chapter 90), Transfer Pricing Aspects of Business Restructurings (Chapter 43).

Hybrid Rules and Transfer Pricing. New Chapter 45.

Cost Sharing casesAmazon and Altera, analyzed in depth and contrasted. see Chapter 13 and Chapter 10.

Tax Cuts and Jobs Act. Revision of U.S. Business Restructuring Chapter 27 includes the impact of GILTI, FDII, BEAT, Transition Tax, on U.S. business’s transfer pricing exposure. BEAT and Service Cost Method are discussed in Chapter 14.

Digital Taxation and Transfer PricingSee new Chapter 44.

Transfer Pricing Review Panel and Transfer Pricing Examination Process Updates. See Chapter 20, Examination and Appeals.

Value Chain Analysis. See Chapter 42, Porter’s Value Chain Analysis Case Study of Amazon; Chapter 97, Value Chain Study of Coffee Industry; Chapter 98, Value Chain Study of the Tobacco Industry.

Taxpayer First Act of 2019. Impact on LB&I Discussed in Chapter 20.

Impact of 2015 APA and Competent Authority Revenue Procedures. Analysis of trends and risks in Chapter 21, APAs and in Chapter 22, Competent Authority.

* * * * * * * * * * * * * * * * * * *

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Advisors will discover a rich selection of Lexis titles examining hot, cutting-edge issues like: Practical Guide to U.S. Transfer PricingLexis Guide to FATCA Compliance; a country-by-country examination of anti-money laundering laws; Taxation of Intellectual Property and TechnologyFederal Taxation of Oil and Gas Transactions; and Foreign Tax & Trade Briefs, which provides summaries of the tax laws and systems of over 120 countries. Nine treatises are authored or co-authored by Professor William H. Byrnes (Texas A&M University Law School) who leads teams of contributing subject experts in analyzing the management of operational and transactional risk confronting tax officers and their advisors, and providing compliance and planning insights.

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