International Transfer Pricing: OECD Guidelines by Richard M. Hammer, Cym H. Lowell, and Marc M. Levey
A step-by-step guide to planning, documentation, design, structure and analysis of international transfer pricing. Whether you are drafting an agreement or analyzing the most current issues, this treatise should be among your primary resources. Includes the full text of the OECD guidelines, an A-to-Z transactional analysis of the penalties and local administrative procedures.
U.S. International Taxation: Practice & Procedure by Cym H. Lowell and Mark R. Martin
This complete procedural resource provides step-by-step guidance to handling all IRS procedures relating to documentation, compliance and controversy handling for all international tax issues. The presentation is transactional in orientation and supported by factpatterns, and addresses all procedural matters.
U.S. International Transfer Pricing by Cym H. Lowell, Peter L. Briger, and Mark R. Martin
Your guide to principles and strategies that have proven effective in the most important area of international tax. The authors develop the substantive law (some 450 cases and relevant regulations), then apply these principles to: transfer pricing studies, presenting positions in a controversy or litigation context, obtaining advance pricing agreements (APAs) and responding to a summons or examination.