Discussion:Advance Pricing Agreement Program with IRS
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| Revision as of 16:07, 14 May 2006 Sandysea (Talk | contribs) (Thank you. I su) ← Previous diff |
Revision as of 14:22, 15 May 2006 Foxttron (Talk | contribs) (Depending on the) Next diff → |
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| {{ForumReplyPost|UserID=Sandysea|Date=14 May 2006|Text=Thank you. I suppose I will enter into the training that IRS offers for it and set it up. The transfer pricing is my biggest concern with this client and this seems like the least hassle in terms of market value approximation. Thanks again!}} | {{ForumReplyPost|UserID=Sandysea|Date=14 May 2006|Text=Thank you. I suppose I will enter into the training that IRS offers for it and set it up. The transfer pricing is my biggest concern with this client and this seems like the least hassle in terms of market value approximation. Thanks again!}} | ||
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| + | {{ForumReplyPost|UserID=Foxttron|Date=15 May 2006|Text=Depending on the quantity of the sales, sec 482 may not apply to your client. TP studies are very cumbersome (and extremely expensive,) but they are "always" better than what the IRS agreement is calling for. See if at least IRC 6662(e) applies to your case; after all, the sales should be more than double or less than half comparing to 3rd parties, and they have some very high thresholds. Again, I would not want to take the IRS at their words when it comes to TP; I have noticed that the usually have no idea about it, but they always bring it up when there are foreign related companies.}} | ||
Revision as of 14:22, 15 May 2006
Discussion Forum Index --> Tax Questions --> Advance Pricing Agreement Program with IRS
| 13 May 2006 | |
| Has anyone entered into this program with IRS and if so, has it been beneficial? My client who is Canadian and his US corporation do not at this point (even with my nagging) have arms length transactions in my opinion. He is not meaning to defraud the US out of taxes, but he has a tough time understanding the concept of arms length.
In order to protect him re Section 482 of the IRC, he can enter this agreement and file with IRS so they do not try and audit his books to determine if he is selling to himself at a comparable rate. Before applying for the program, I wanted to see if any of you have had any involvement with it. Thanks! | |
Inagpurwala (talk|edits) said: | 14 May 2006 |
| I was involved indirectly at Altera Corporation, San Jose, CA. Tax Director there worked on this project and negociated the pricing (in 1998-1999). That brought final tax rate to 17%(if I remmember correctly).
So answer to your question, yes it does help reducing the tax rate. Altera Corporation manufactures PLDs and sales in the USA and the international market. Unfartunatley I do not know all the detail how to enter into the APA. I nolonger work at Altera.Inagpurwala 21:27, 13 May 2006 (CDT) | |
| 14 May 2006 | |
| Thank you. I suppose I will enter into the training that IRS offers for it and set it up. The transfer pricing is my biggest concern with this client and this seems like the least hassle in terms of market value approximation. Thanks again! | |
| 15 May 2006 | |
| Depending on the quantity of the sales, sec 482 may not apply to your client. TP studies are very cumbersome (and extremely expensive,) but they are "always" better than what the IRS agreement is calling for. See if at least IRC 6662(e) applies to your case; after all, the sales should be more than double or less than half comparing to 3rd parties, and they have some very high thresholds. Again, I would not want to take the IRS at their words when it comes to TP; I have noticed that the usually have no idea about it, but they always bring it up when there are foreign related companies. | |
