The Potential Impact of the Application of Transfer Pricing Principles to Foreign Tax Credit Analysis for Inter-Branch Transactions of US-based Multinational Enterprises (PDF)
In this Emerging Issues Analysis, Dale Bond, Elizabeth Sweigart, and Alan Fischl of PricewaterhouseCoopers LLP examine Chief Counsel Advice 201349015, which applies transfer pricing principles to foreign tax credit analyses of certain transactions between related parties that would not result in income for US federal income tax purposes, such as those between a foreign branch or foreign disregarded entity and its US corporate owner.
Dale Bond, Elizabeth Sweigart, and Alan Fischl are with PricewaterhouseCoopers LLP. Dale, a Partner at PwC, has nearly 25 years of experience providing international tax and transfer pricing advisory services to clients in a variety of industries including oil and gas, consumer products, and high technology. He holds a BBA and MS in Accountancy from Texas Tech University. He can be reached at email@example.com. Liz, a Director at PwC, has over a decade of transfer pricing, tax controversy, and project management experience. She earned a BA from Rice University and an MBA from the University of St. Thomas (Houston). She can be reached at firstname.lastname@example.org. Alan, a Principal, has over 33 years of experience as an international tax advisor. He served as a legislation attorney with the Congressional Joint Committee on Taxation where he was a principal participant in the development and drafting of the international provisions of the Tax Reform Act of 1986. He is a past Chair of the Foreign Activities of US Taxpayers Committee of the American Bar Association Tax Section. Alan holds an AB from Brandeis University and a JD from Harvard Law School. He can be reached at email@example.com. Learn more about PwC at http://www.pwc.com.
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