The Importance of Transfer Pricing Essays

The week four individual paper addresses the implementation of Activity Based Costing (ABC) by Super Bakery, Inc., a virtual corporation founded by Franco Harris. Specifically, management strategies, the reasoning behind an ABC system, and the alternatives of a job order cost system or a process order cost system are assessed for this enterprise.

The price ceiling is the maximum price a seller is allowed to charge for a product or service. An impact on society includes when the prices are so high of a product, that no one can buy it. A price floor is the lowest legal price a product or service can be sold at. When market price is at its lowest, it may still be too high for consumers to purchase products. Governments can intervene for any purpose, and they are the ones who set these price controls.

The "transfer pricing" provision attempts to identify the taxable income had the transaction been between unrelated parties dealing at arm's length.

However, the companies only have to pay the U.S. tax for foreign revenues once they bring the profits back to the United States. As a result of these current tax laws, U.S. companies that seek to avoid high corporate tax rates hold their foreign earned profits overseas. “It just makes no sense to pay a substantial tax on it,” said Joseph Kennedy, a senior fellow at the Information Technology and Innovation Foundation (Rubin, R.). It is far too easy for an IT corporation to create a patent in a foreign country and direct revenue to a corporation within that country, thus avoiding the much higher U.S. tax rates. According to Joint Committee on Taxation estimates, the lost revenue is increasing over time as corporations find even more creative ways to make their U.S. profits look like offshore income (Richards, K., & Craig, J.). As result, multinational American corporations have as much as $2 trillion held in overseas subsidiaries and if brought into the United States with the current tax laws, the federal government could benefit by nearly $50 billion per year.

Throughout years large American industrial companies have been running away from U.S. taxes, but there has been a new change. Companies such as Apple and Google have been affected by a change foreign countries are going through collecting higher taxes than before. It seems as if no longer can these companies get away with paying low taxes. This is happening because the European Commission have passed an order to collect high taxes. One example is Ireland who was ordered to collect fourteen billion dollars from Apple, which brought a surprise to this company. Companies have run out of places to run and pay one percent or less of taxes in foreign places, instead of paying back home.

The main objective of many companies is to minimize their tax obligations. Jeffers (2014) discussed the reason of why companies adopt tax inversion strategies. The researcher indicated that the income maximization is a major reason of companies attempting to reduce their tax liability (pp. 100-101). Tax inversion strategies provide companies an advantage to lower income tax rate. Today, U.S. corporations renounce its U.S. citizenship and move to low-tax countries. Companies that reincorporate oversees are not obligated to pay U.S. taxes on earning income (p. 99). Many countries implement tax competition strategies to attract and retain businesses. Well-known companies, such as Exxon Mobil, Hewlett Packard, Tyco, General Electric, PepsiCo, etc. take benefits of tax shelter opportunities overseas (p. 102). Other benefits of the jurisdiction abroad are flexible banking laws and simplified litigation processes.

Finally, in order to complete a more accurate comparison between the two projects, we utilized the EANPV as the deciding factor. Under current accepted financial practice, NPV is generally considered the most accurate method of predicting the performance of a potential project. The duration of the projects is different, one lasts four years and one lasts six years. To account for the variation in time frames for the projects and to further refine our selection we calculated the EANPV to compare performance on a yearly basis.

A Tax Inversion is a business transaction in which a company, typically residing in the U.S., merges with a foreign company and moves its corporate headquarters overseas while maintaining its main operations in the U.S. for strategic purposes; specifically to take advantage of the lower tax rules in the foreign country. Even though, this practice has progressively increased in the last two decades, Congress is not so enthusiastic with the idea of corporations trying to avoid a

To obtain long term solutions it is critical that the American government reshapes the tax code and provides Americans a substantial amount of tax relief. The current tax code is too complicated, it needs to be simplified. The way the current tax code is organized it seems that it someone needs an advanced degree in order to effectively understand and complete it. Simplifying the tax code will be beneficial to the average citizen and the government. This country needs to effectively increase the economic developments within its boundaries. To allow substantial economic development this government is absolutely necessary that this country put an end to corporate inversion. The biggest factors that contribute to corporate inversion are the incredibly high tax rate of thirty five percent and the decision by the American government to force a tax on company’s income, regardless of their location. By lowering the corporate tax rate and allowing to America to transition from an international system to a more domestic one, corporate inversion will end which will add a enormous amount money back into the American economy. These long term solutions will give America permanent solutions to the horrible tax problems it faces

Americans may ponder the thought of struggling economy barely gaining momentum while corporations have witnessed some of the largest quarterly profits ever recorded. The driving force behind the extreme profits gained by many corporations is simply put as tax inversion. Tax inversion is nothing more than an American firm combining with a foreign firm in a country with beneficial and lucrative tax laws (Financial Times, 2014). The American headquarters will now be moved to the new foreign firm where they will enjoy the lower taxes and evade the taxation of the United States government (Financial Times, 2014). More and more American firms have been taking advantage of inversion while still being able to enjoy sales in the American market.

If it is included, then profit will be decreased. The Fifth and Eighth Circuits have taken an approach that foreign taxes are not economic costs and should not be deducted from pretax profit. However, in the Second Circuit, the court in BNY concluded that the objective prong of the economic substance test requires the inclusion of foreign taxes in both a calculation of pre-tax profit and a consideration of the transaction’s overall economic effect. The court supports its decision with the congressional intent that foreign tax credits are to “facilitate global commerce by making the IRS indifferent as to whether a business transaction occurs in this country or in another, not to facilitate international tax arbitrage.” Taking into consideration the tax spread, the Bx payment, and the U.K. taxes paid by the trust, the transaction does not generate profit and thus fails the objective prong of the

Today’s highly competitive business world forces companies to create different tactics and relatively rely on multiple pricing strategies to conduct business.

Opportunity cost is the value of the next best alternative in a decision. Imagine that you have $150 to see a concert. You can either see "Hot Stuff" or you can see "Good Times Band." Assume that you value Hot Stuff's concert at $225 and Good Times' concert at $150. Both concerts cost $150 per ticket, but it would take you a couple of hours to drive to Hot Stuff's concert and you have to be in school (the next) morning for an exam. Good Times' concert is right here in town. Explain how you would assess the opportunity cost of seeing Good Times in concert. What is the opportunity cost of going to Good Times' concert?

We are providing below the assumptions and other calculations we used while computing the WACC and the cash flows.

Write a 1200-1500 word paper that describes a strategic compensation plan for machine operators at Plastec Company. Refer to the description from the week 3 assignment. Include at least 3 referenced articles and cite them as appropriate. This paper should at a minimum address the following: