Boeing Co.: the Supreme Court interprets the R and D apportionment regulations

Article Abstract:

In the case of Boeing Co., the Supreme Court ruled on transfer pricing methods used by the airplane manufacturer to attribute as much research and development income as possible to its d omestic international sales corporation and foreign sales corporation subsidiaries. This would result in tax benefits. In ruling against Boeing in this case, the Court is open to criticism on several fronts.

Legal issues & crime, Government regulation (cont), Research and Development in the Physical, Engineering, and Life Sciences, Government regulation, Scientific Research and Development Services, Taxes, Legal/Government Regulation, Commercial physical research, Research & Development-Industry, Science, Research & Development, Corporate Income Taxes, Laws, regulations and rules, Research and development, Industrial research, Tax accounting, Foreign sales corporations, Domestic international sales corporations

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The real world of transfer pricing today

Article Abstract:

A panel discussion centering around transfer pricing and the operation of IRC section 482 is presented. Panelists discussed issues including penalty administration, changes in documentation rules, privileged information, the meaning of 'commensurate with income', and international treatment.

Tax Law, International, Panel Discussion, Intangible property, Intangible assets

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Imperfections of competent authority relief

Article Abstract:

The authors discuss problems with competent authority relief in the administration of income tax treaties, focusing on transfer pricing procedures which can lead to double taxation.

Interpretation and construction, Prevention, Tax treaties, Double taxation

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