Transfer Pricing Planning and ControversyDuring the years of his Big 4 service, Mr. Cope developed a wide range of experience in transfer pricing planning and transfer pricing controversy. Mr. Cope has a degree in economics from the University of Chicago, and he regularly works with economists developing and implementing transfer pricing strategies for mutinational enterprises. He can offer practical transfer pricing advice on a wide range of issues in a variety of industries. Mr. Cope also has experience in managing and successfully resolving disputes over transfer pricing issues.
Services that may be charged out at cost; Services that may not be charged out at cost; Methods for determining the markups on services; the U.S. approach to services v. other countries.
Methods for pricing transfers of tangible property; customs valuations and section 1059A.
Methods for determining arm’s length interest rates; The safe-harbor interest rates and when they are available; Guarantee fees; Relationship among sections 481, 482 and 7872.
See: Intellectual Property Planning
Transfer pricing issues faced by foreign banks operating in the United States.
Documentation and Penalties
U.S. documentation standards; Specified methods and chocie of the best method; Field agents’ preferred methods v. the court’s preferred methods; Pros and cons of in-house documentation; Working with economists.
Managing Transfer Pricing Controversy Risk
APAs (when to consider an APA, what is required for an APA, unilateral v. bilateral APAs); Self-help (qualified amended returns, pros and cons of self-initiated adjustments and Rev. Proc. 99-32); Avoiding double taxation resulting from a transfer pricing adjustment with a MAP (pros and cons of MAPS, when to initiate a MAP, what a MAP costs in time and money); Protecting your foreign tax credits; Correlative adjustments; Setoffs.