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Transfer pricing adjustments have been a feature of many tax systems since the 1930s. The United States led the development of detailed, comprehensive transfer pricing guidelines with a White Paper in 1988 and proposals in 1990–1992, which ultimately became regulations in 1994. [33]
On December 24, 2014, the Seattle Times reported that the IRS sued former Microsoft CEO Steve Ballmer, Craig Mundie, Jeff Raikes, Jim Allchin, Orlando Ayala and David Guenther in an effort to compel them to testify in Microsoft's corporate tax audit. The IRS has been looking into how Microsoft and other companies deal with transfer pricing. [11]
The Fund Transfer Pricing (FTP) measures the contribution by each source of funding to the overall profitability in a financial institution. [1] Funds that go toward lending products are charged to asset-generating businesses whereas funds generated by deposit and other funding products are credited to liability-generating businesses.
An advance pricing agreement (APA) is an ahead-of-time agreement between a taxpayer and a tax authority on an appropriate transfer pricing methodology (TPM) for a set of transactions at issue over a fixed period of time [1] (called "Covered Transactions").
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For example, if you have a card with a $5,000 balance transfer limit and a 3 percent balance transfer fee, the most you’ll be able to transfer is about $4,850. That transfer amount plus the 3 ...
Some jurisdictions extend the audit requirements to include opining on such tax issues as transfer pricing. [citation needed] Jurisdictions not relying on financial statement income must attempt to define principles of income and expense recognition, asset cost recovery, matching, and other concepts within the tax law. These definitional issues ...
Some banks limit how often you can transfer money out of a savings account. Exceeding the allowed quota of transfers via ATM, electronic bill payment or other methods could result in being charged ...
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