ransfer Pricing Publications

"Transfer Pricing Documentation: Caveat Emptor" with Jerrie Varrone Mirga Tax Management Transfer Pricing Report. August 11, 1999. Tax Management, Inc. a subsidiary of The Bureau of National Affairs. pp. 359-365.

"Arm's Length or Formulary Apportionment? Sometimes the Best Choice is Both" Tax Management Transfer Pricing Report. June 2, 1999. Tax Management Inc. pp. 94-104.

"Finding the Best Method: A Tax Executive's Approach to Transfer Pricing" Tax Management Transfer Pricing Report. July 19, 1995. Tax Management, Inc. pp. 181--191 [Reprinted in Representing the Corporation: Strategies for Legal Counsel. Ed. Richard H. Weise. 1996 Aspen Law & Business]

"R&D Cost Sharing Under the U.S. Proposed Regulations" Tax Management Transfer Pricing Report. April 27, 1994. Tax Management Inc. pp. 844-850

"German Court Issues Important Decision in Transfer Pricing Case" with Klaus Sieker and David Benson. Tax Notes International. September 13, 1993. pp. 671-673.

"Use of Averages and Other Statistical Techniques Under IRC ß482" Tax Management Transfer Pricing Special Report. August 4, 1993. Tax Management Inc. 26 p.

"Taxes Paid by Foreign-Owned Companies: We Need More Information To Determine Whether They Are Too Low" Tax Notes International. July 5, 1993. pp. 45-50.

"The Role of Economic Analysis in Transfer Pricing Compliance, Audits, and Litigation" U.S. Taxation of International Operations Warren Gorham Lamont, Research Institute of America, Inc. 1992. [Updated March 12, 1997.]

"An Economic Approach to Transfer Pricing Policies" in Transfer Pricing: The International Tax Concern of the '90s Cym H. Lowell, Philip D. Morrison, H. David Rosenbloom, and Karla W. Simon, Eds. Prentice Hall Law & Business. Fall 1991. pp. 7-24.

"A Practical Approach to the Tax Treatment of Reinsurance" with C. Clinton Stretch, Value Enhancement Strategies for Mid-Sized Life Insurance Companies Institute for International Research. October 1990.

"Bausch & Lomb Provides Insight Into Tax Court's Sec. 482 Analysis" with Catherine Fleischmann, The Tax Advisor December 1989. pp. 815-816

Valerie Amerkhail

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