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ARTICLE · 31 JULY 1996

051b. Transfer Pricing - Where We Stand - Developments in the United States

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INDEX

1.1 U.S. Record-Keeping Requirements (section 6038A IRC)
1.2 U.S. Accuracy-Related Penalties (section 6662 (e) IRC)
1.3 U.S. Transfer Prices And Customs Value (section 1059A IRC)
1.4 New U.S. Transfer Pricing System (section 482 and Reg. sec. 1.482 
    IRC)
    In General
    Comparable Profits Method
    Arm's Length Principle
    Best Method
    Transfer Price Methods
    Arm's Length Range
    Market Entry, Defence, And Expansion Strategies
    Functional Analysis
    Intangible Assets
    Procedural Matters
1.5 U.S. Advance Pricing Agreements

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