1. Your client is a multinational corporation and is planning to manufacture certain products in a low tax international subsidiary that is 100% owned. The subsidiary would manufacture and sell the products to the US parent, and the parent would sell to unrelated customers.

a. Summarize the functions and risks that the company should consider in developing the transfer pricing documentation for this transaction.

b. What financial reporting and tax return matters should the company consider?

c. What information should you request from the client?