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Leslie Bonacum
Neil Allen

New Resource From CCH Offers Expert Guidance On Transfer Pricing Rules, Practice

(RIVERWOODS, ILL., March 20, 2001) Ė The stakes are high, and companies that donít know the rules and how to apply them can lose big when their transfer pricing arrangements are challenged by taxing authorities, according to CCH INCORPORATED (CCH), a leading provider of tax and business law information and software. To help companies and their tax advisors develop sound pricing strategies, CCH has published a new book that not only explains the rules, but shares the priceless experience of two leading experts in the field of structuring transfer policies and resolving disputes regarding them. Transfer Pricing: Rules, Compliance and Controversy, by Marc M. Levey and Steven C. Wrappe is a complete guide to setting transfer prices, documenting them and defending them in a variety of forums. (462 pages, $155. To order, call CCH at 1-800-248-3248 or visit the CCH online store at Visit to view table of contents and a chapter excerpt.)

Biggest Item on Audit

"Transfer pricing is often the biggest item that can be addressed in an IRS audit," said Gail Portugal, marketing manager for the CCH Federal and State Tax group. "The IRS has asked for some enormous adjustments on audit, with correspondingly steep penalties and statutory interest. Whatís more, any changes in the pricing system will also change the companyís books and records and even management compensation."

Transfer Pricing: Rules, Compliance and Controversy begins by examining the statutory and regulatory framework that governs transfer pricing. The authors then lay out the methods used for sales and other transfers of many types Ė those of tangible and intangible property, intercompany services, cost-sharing arrangements and financing transactions. Tax Court cases that have addressed each method are also analyzed. The authors also explore the nuances of the Code Sec. 482 regulations, such as blocked income, and the OECD approach to transfer pricing.

The focus of the book then shifts to questions of compliance and resolving controversies, beginning with the development of an overall compliance strategy.

The authors then provide a detailed look at the range of penalties that might be sought in transfer pricing cases, preparing transfer pricing documentation, pre-examination preparation and the transfer pricing examination process itself. Three chapters then review post-examination procedural alternatives by first analyzing the choice between unilateral and bilateral procedures and then walking through each alternative in detail.

The book concludes with chapters on transfer pricing for e-commerce transactions, customs valuation issues and miscellaneous compliance issues relating to the statute of limitations, privileges against disclosure and documentation of agreements.

A useful appendix is filled with practice tools, including forms, flow charts and illustrative analyses.

About the Authors

The authors of Transfer Pricing: Rules, Compliance and Controversy are two acknowledged experts in the field.

Marc M. Levey is a nationally recognized expert in international taxation, especially in structuring and defending transfer pricing strategies. He is a partner with the New York office of Baker & McKenzie and has significant experience structuring foreign investment in the United States and structuring intercompany pricing policies and programs in the United States and in numerous foreign jurisdictions.

Steven C. Wrappe is the Director of APA services for Deloitte & Touche LLP in the firmís National Tax Office in Washington, D.C. He represents the firmís largest clients in the IRS APA program, before the U.S. and foreign competent authorities and in transfer pricing examinations and appeals.

Availability and Pricing

For more information or to purchase the 462-page Transfer Pricing: Rules, Compliance and Controversy, contact CCH at 1-800-248-3248 or visit the CCH online store at Single-copy price is $155 plus applicable tax, shipping and handling. Quantity discounts and school adoption pricing are available.


CCH INCORPORATED, headquartered in Riverwoods, Ill., was founded in 1913 and has served four generations of business professionals and their clients. The company produces more than 700 electronic and print products for the tax, legal, securities, insurance, human resources, health care and small business markets. CCH is a wholly owned subsidiary of Wolters Kluwer North America. The CCH web site can be accessed at The CCH Federal and State Tax Group web site can be accessed at

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