Courses 2009 - 2010
LAW T 524
Transfer Pricing Seminar
This course reviews section 482 of the U.S. Internal Revenue Code (IRC) and the Treasury regulations thereunder, with a focus on multinational corporations (MNCs) and their related party transactions that are subject to the arm's length standard. Students will learn to apply U.S. transfer pricing regulations to a variety of related party transactions involving MNCs including transfers of intangible property and tangible property and the provision of services. Particular emphasis will be placed on intangible property transactions. The course also emphasizes issues associated with the global allocation of profits attributable to functions performed, risks incurred and resources employed. T515 International Taxation I is required for students to enroll in the course.
Not offered this academic year.