This chapter from a Practical Guide to Transfer Pricing (Lexis) compares the U.S. Section 482 transfer pricing regulations to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations as revised in 2010. Section 482's purpose is to ensure that taxpayers subject...

This paper assesses the impacts of the 2017 tax reform act on U.S. competitiveness in terms of changes in incentives for U.S. domestic corporate investment and the taxation of U.S.-headquartered companies and their foreign subsidiaries relative to foreign-headquartered companies. The reduction...

This paper examines the effects of the Tax Reform Act of 1986 on the international location decisions of U.S. financial services firms. The Act included rule changes that made it substantially more difficult for U.S. firms to defer U.S. taxes on overseas financial services income held in low-tax...