This book draws on the extensive experience of the international tax lawyers in the Baker a McKenzie North American Tax Practice Group to present a clear and concise practical guide To The new 1993 intercompany transactions to avoid future controversy and minimize exposure To The stiff new penalties established by these new rules, and discusses how these new rules will affect future controversies with the Internal Revenue Service.guide to the new 1993 United Statesrules Baker aamp; McKenzie. ... of pricing is aquot; clearly more appropriateaquot; under the facts and circumstances of its particular case, a fourth method can be ... United States, 608 F.2d 445 (Ct. CL 1979), cert, denied, 445 U.S. 962 (1980) (where the court relied on ratios of gross income to operatinganbsp;...
|Author||:||Baker & McKenzie. North American Tax Practice Group|
|Publisher||:||Kluwer Law Intl - 1993-11-12|