Description of Revenue Provisions Contained in the President's Fiscal Year 2011 Budget Proposal, August 16, 2010
Description of Revenue Provisions Contained in the President's Fiscal Year 2011 Budget Proposal, August 16, 2010

Author: United States. Congress. Joint Committee on Taxation

Publisher: Joint Committee on Taxation

Published: 2010

Total Pages: 532

ISBN-13:

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NOTE: NO FURTHER DISCOUNT FOR THIS PRINT PRODUCT--OVERSTOCK SALE -- Significantly reduced list price This document, prepared by the staff of the Joint Committee on Taxation, provides a description and analysis of the revenue provisions modifying the Internal Revenue Code of 1986 (the "Code") that are contained in the President's fiscal year 2011 budget proposal, as submitted to the Congress on February 2010. The document generally follows the order of the proposals as included in the Department of the Treasury's explanation of the President's budget proposal. For each provision, there is a description of present law and the proposal (including effective date), a reference to relevant prior budget proposals or recent legislative action, and an analysis of policy issues related to the proposal.

Transfer Pricing and the Arm's Length Principle in International Tax Law
Transfer Pricing and the Arm's Length Principle in International Tax Law

Author: Jens Wittendorff

Publisher: Kluwer Law International B.V.

Published: 2010-01-01

Total Pages: 914

ISBN-13: 9041132708

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The arm's length principle serves as the domestic and international standard to evaluate transfer prices between members of multinational enterprises for tax purposes. The OECD has adopted the arm's length principle in Article 9 of its Model Income Tax Convention in order to ensure that transfer prices between members of multinational enterprises correspond to those that would have been agreed between independent enterprises under comparable circumstances. The arm's length principle provides the legal framework for governments to have their fair share of taxes, and for enterprises to avoid double taxation on their profits. This timely book contains a comparative analysis of the legal basis for the arm's length principle and the contents of the arm's length rules in US tax law as well as in the OECD Model Tax Convention and Transfer Pricing Guidelines. It includes a thorough review of international case law on transfer pricing from the United States, Canada, Australia, United Kingdom, Germany, France, the Netherlands, Denmark, Sweden, and Norway. The book ends with an analysis of the issues associated with the application of the arm's length principle for multinational enterprises in a global economy.