Haunted House Pg 596-600 Spooky Mansion pg 601-607 Hash Slinging Slasher pg 586- 590 Walking Dead International pg 607-611 This is the End Pg 590-595
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Arm's Length
Section 482 requires transactions between commonly controlled entities to be carries out at ________ prices
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Comparable uncontrolled transaction
This method determines whether or not the amount a company charges a related party for the use of intangible property is an arm’s-length price by
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Negotiated price
This transfer price is the result of negotiation between buyer and seller?
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Foreign parent companies with branches and subsidiaries in the United States.
Which group has negotiated the greatest number of advance pricing agreements with the U.S. Internal Revenue Service (IRS)?
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Downstream sale
What do you call selling goods and services to a foreign subsidiary?
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Comparable uncontrolled price
The ___________ method is generally considered to provide the most reliable measure of arm’s-length price when a comparable uncontrolled transaction exists
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Safe Harbor
A _____ rule exists when the loan is denominated in U.S. dollars and the lender is not regularly engaged in the business of making loans to unrelated persons.
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1) The market for the product is perfectly competitive
2) Interdependencies between the related parties are minimal
3) there is no advantage or disadvantage to buying and selling the product internally rather than externally
Market based transfer prices lead to optimal decisions when… (3 things)
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Penalties and interest on overdue tax.
Uncertainty as to the group’s worldwide tax burden.
Problems in relationships with local tax authorities
The risks associated with local tax authorities scrutinizing a company’s transfer prices are:
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lower-tax country)
The most well-known use of discretionary transfer pricing is to minimize world-wide income taxes by recording profits in
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Final selling price
In order to use the resale price method, a company must know the ______ _______ ______ to uncontrolled parties and able to determine an appropriate gross profit for the reseller.
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Mutual Agreement Procedure
When confronted with an IRS transfer pricing adjustment, a taxpayer may request assistance from the U.S. Competent Authority through its
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intangible property
Royalty and Licensing fees are associated with the use of ?
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Political Reasons
Worldwide, there are certain types of transfers and certain industries that are more at risk for examination by tax authorities. For example, imports are more likely to be scrutinized than exports, partly for
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(arms’ length prices
Prices that would be charged between independent parties in the same circumstances is said to be made at …
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Profit Split method
Which method assumes the buyer and seller are one unit
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130
The stated interest rate is considered to be at arm’s length if it is at a rate not less than the “applicable federal rate” and not greater than _____ percent of the applicable federal rate?
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Division
Business enterprises often are organized by…
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less profitable than the tax authority believes it should be
There are several red flags that can cause a tax authority to examine a company’s transfer prices. The most important of these is if the company is
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Double Taxation
What happens when a price is accepted by a country but disallowed by another
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Level of the market
Foreign currency risk
Geographic market in which transaction takes place
3 factors that the Treasury Regulations lists as relevant in determining whether an uncontrolled transaction is comparable
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20%
A penalty equal to ______ percent of the underpayment in taxes may be levied for a substantial valuation misstatement.
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Transfer Pricing
refers to the determination of the price at which transactions between related parties will be carried out.
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Analysis
Application
Due diligence
What Does the APA process consist of (3)
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Minimization of Tariffs
Avoidance of Withholding Taxes
2 cost-minimization objectives






Chapter 12 Jeopardy

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