This article springs from two concurrent phenomena. First, U.S. federal deficit spending projections indicate that any feasible deficit reduction plan will require substantial additional revenue. Second, the U.S. system for taxing foreign-source income is so badly flawed that if the United...

Transfer pricing rules in India, were introduced in 2001, however, there are issues of tedious documentation, complicated procedures, rigorous penalties. Therefore, this subject has emerged as biggest source of courtroom battles. Recently, system has been improved by incorporating APAs, SHRs,...

This paper brings forward a three-country model to analyze the internationalization process in the age of globalization. It is shown that investment of one company increases not only the incentive to invest in another country for every national competitor but for third country's companies as...

This paper aims at providing a comprehensive overview of existing literature on the topic of comparability adjustments. Based on existing literature the most commonly used adjustments can be categorized in two broad categories: “accounting and financial risks adjustments” and...