Analyze how internal revenue service uses irc

Assignment Help Accounting Basics

Reference no: EM132470395 , Length: 7

Assignment: Intercompany Pricing

Transfer pricing is important to multinational entities and tax administrators. Transfer pricing involves transactions between affiliated entities domiciled in different countries creating different tax requirements. Profit determination of multinationals generated by intra-company transactions is one of the most challenging issues in international taxation.

Question 1: Identify a multinational company that engages in cross border transactions in two (2) foreign countries. Suppose that this company has engaged you to provide advice on intercompany pricing to achieve the lowest combined taxes for all jurisdictions.

Using the Internet or Strayer Library, research the rules and techniques for transfer pricing. Choose two (2) foreign countries and research their respective tax rates.

Write a five to seven (5-7) page paper in which you:

Question 1: Provide the name of the company you've selected and what type of international business they are engaged in. Based on your research, create projections of revenues, costs, and tax rates based on the company's transaction in the two (2) countries researched and the U.S.

Question 2: Create a scenario in which you allocate revenues and costs to each country to determine the lowest possible overall tax for each country. Provide support for your allocations.

Question 3: Propose a scenario to the client that will result in a favorable tax position. Provide support for your position.

Question 4: Analyze how the Internal Revenue Service (IRS) uses Internal Revenue Code (IRC) section 482 to prevent shifting of profits to other countries to reduce U.S. tax liability.

Question 5: Assume that the IRS has challenged the allocations and is preparing to audit the client. Prepare a brief position to defend the client to the IRS. Provide support for your position.

Question 1: Evaluate two (2) tools IRS agents have available to perform the audit on multinational transfer pricing issues.

Use at least five (5) quality resources in this assignment.

Reference no: EM132470395

Questions Cloud

Demonstrate understanding of quantitative research : This assignment provides a learning activity for students to demonstrate understanding of quantitative and qualitative research, the purpose and importance.

Determine and prepare a flexible budget report for the year : What course of action do you recommend for the management of Green Pastures? Did management do a good, average, or poor job of controlling expenses?

Determine advantages and disadvantages of equity financing : Determine Advantages and disadvantages of equity financing. Identify how firms raise funds through the use of debt, equity, and retained earnings.

Identify at least 3 interdisciplinary team members : Identify at least 3 interdisciplinary team members that may be involved in a pediatric trauma beginning with the onset of injury to home care.

Analyze how internal revenue service uses irc : Analyze how the Internal Revenue Service (IRS) uses Internal Revenue Code (IRC) section 482 to prevent shifting of profits to other countries

Develop a simple infographic to help explain the concepts : Consider how knowledge may be informed by data that is collected/accessed. Develop a simple infographic to help explain these concepts.

Hlsc641 introduction to health sciences research assignment : HLSC641 Introduction to Health Sciences Research Assignment Help and Solution, Australian Catholic University - Assessment Writing Service

Determine the capstone research project : Assess the potential for fraud within Durango based on the lack of IT controls, and determine at least two (2) ways Durango will structure internal IT control

Analyze diagnostic criteria for personality disorders : Analyze diagnostic criteria for personality disorders. Analyze evidence-based psychotherapy and psychopharmacologic treatments for personality disorders

User Account

All Pages