December 21, 2022 In the Stacks

Tax Section Publishes The Fundamentals of U.S. Transfer Pricing

This month, the ABA Tax Section is publishing the new book The Fundamentals of U.S. Transfer Pricing, by Steven C. Wrappe. The book explains transfer pricing and its importance, including its role in the world’s largest tax disputes and the resulting financial reporting issues.

Transfer pricing is a significant tax and accounting issue for multinational entities with substantial related party transactions. It is a complex fair market value concept that affects taxable income in multiple jurisdictions, customs valuations, state taxes, and financial reporting. The transfer pricing issue is present in nearly half of U.S. import and export transactions, and it consistently produces tax disputes in the tens of millions and billions of dollars.

The Fundamentals of U.S. Transfer Pricing provides a comprehensive overview of transfer pricing. It explains the business need and policy underpinnings for transfer pricing and the unique concepts that drive transfer pricing analysis. The book uses helpful charts, diagrams, and formulas to explain the individual steps in transfer pricing analysis and how to apply that analysis to different types of transactions. Finally, it explores penalty rules, controversy procedures, and ways to avoid transfer pricing disputes.

“Everyone who deals international transactions needs to understand transfer pricing,” notes Wrappe. “The impact of transfer pricing on international business decisions is too integral to be ignored.”

Wrappe is Grant Thornton’s Transfer Pricing Technical Leader in its Washington National Tax Office. He is a globally recognized transfer pricing expert, with over 25 years of experience in transfer pricing planning, compliance, and controversy for large multinational clients. During that time, he has been a Senior Attorney with the IRS Advance Pricing Agreement (APA) Program, a partner with a global law firm, and the transfer pricing controversy leader at Big Four Firms. He has cowritten a transfer pricing treatise in its fifth edition and has taught transfer pricing in the tax programs at Georgetown University Law Center, University of Florida, and New York University for over 20 years.

The Fundamentals of U.S. Transfer Pricing draws together the core steps and concepts of the transfer pricing analysis into a coherent whole,” said Elizabeth J. Stevens, Caplin & Drysdale. “Steve Wrappe has demystified transfer pricing for the novice and created a user-friendly reference for the experienced practitioner.”

The book is designed for in-house tax lawyers and practitioners of international tax at all levels, as well as for LL.M., M.S.T., and M.B.A. students studying global businesses. The Fundamentals of U.S. Transfer Pricing is part of the Tax Practitioner Guide Series and is available for purchase in the ABA Store in paperback and ebook formats.

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