An interview with Steven D. Harris and Karl Kellar of the APA Program

Article Abstract:

IRS Advance Pricing Agreement (APA) Program branch chiefs Steven D. Harris and Karl Kellar believe that the procedures detailed in Revenue Procedure 96-53 on APAs are a result of accumulated wisdom on how to best promote compliance and certainty. The primary changes to the APA process are negotiations at an earlier stage of the process and revision of bilateral and multilateral request processing. No particular transfer pricing methods are favored by the IRS, and the IRS is not considering making some APA requests penalty-proof.

Public Finance Activities, Corporate Income Taxes, Management, Officials and employees, Taxation, Interview, United States. Internal Revenue Service, Tax compromises, Related party transactions, Harris, Steven D., Kellar, Karl

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Transfer pricing analysis of global trading operations and procedural alternatives

Article Abstract:

Multinationals continually seek single taxation of profits by using transfer pricing methodologies to appropriately apportion profits among various jurisdictions. Global trading raises a number of issues vis-a-vis proper transfer pricing strategy. For example, 94-40 cases utilizing a single profit center and formula apportionment involve somewhat different considerations than inbound intrabrand situations. Issues of capital, risk, and centralized trading within a traditional transfer pricing situation are also examined.

Multinational Corporations

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