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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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