The White Paper dismisses the prospect of double taxation rather cavalierly. relying on the competent authority and US foreign tax credit mechanisms. both of which would be inadequate to solve the problems of foreign country ... The solutions given in the examples in the White Paper are simplistic in the extreme. compared to the enormous work and potential ... As will be seen in greater detail later in this article. however. the arma#39;s-length return method. which is the central IRSanbsp;...
|Title||:||Transfer pricing for intangibles|
|Author||:||Fred C. de Hosson|
|Publisher||:||Kluwer Law Intl - 1989-05-01|