Transfer pricing

This week, a Transfer Pricing Exec Ed Program at Duke is being taught by my old friend from government service, Peter Barnes. I’ve been sitting in some, and am to speak tomorrow (against the separate entity and for formulas, as much as possible).

International is the hardest part of tax.
Transfer pricing is the hardest part of international.
Intangibles are the hardest part of transfer pricing.

A lot is new. For the first time in years, I’ve heard people talk about a “real country” – one that’s not a tax haven, or phony country.

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