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I need a tutoring for assignment 4: Intercompany Pricing, can you help me? Using the Internet or Strayer Learning Resource Center, research the rules and
I need a tutoring for assignment 4: Intercompany Pricing, can you help me?
Using the Internet or Strayer Learning Resource Center, research the rules and techniques for transfer pricing. Choose two (2) foreign countries and research their respective tax rates.Write a five to seven (5-7) page paper in which you:
- Based on your research, create projections of revenues, costs, and tax rates based on the two (2) countries researched and the U.S.
- Create a scenario in which you allocate revenues and costs to each country to determine the lowest possible overall tax for each country. Provide support for your allocations.
- Propose a scenario to the client that will result in a favorable tax position. Provide support for your position.
- Analyze how the Internal Revenue Service (IRS) uses Internal Revenue Code (IRC) section 482 to prevent shifting of profits to other countries to reduce U.S. tax liability.
- Assume that the IRS has challenged the allocations and is preparing to audit the client. Prepare a brief position to defend the client to IRS. Provide support for your position.
- Evaluate two (2) tools IRS agents have available to perform the audit on multinational transfer pricing issues.
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