International Taxation: Problems Persist in Determining Tax Effects of Intercompany Prices

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Report Type	Reports and Testimonies
Report Date	June 15, 1992
Report No.	GGD-92-89
Subject	Foreign investments in US International trade regulation Management information systems Profits Tax administration Tax administration systems Tax evasion Tax law Income taxes Foreign corporations

Summary:

During the 1980s, the amount of direct foreign investment in the United States rose dramatically--from $83 billion to $401 billion. The share of world manufacturing trade between related parties also increased significantly. Concerns have been raised in Congress about inappropriate transfer pricing practices. In 1986 foreign-controlled corporations--U.S. firms in which at least a certain percentage of voting stock is held by a foreign party--reported losses of about $1.5 billion, despite posting more than $540 billion in receipts that year. This report examines (1) whether foreign-controlled companies might have underpaid income taxes by improperly using transfer pricing; (2) what factors, if any, affected the Internal Revenue Service's ability to determine and recover any potentially underpaid taxes; and (3) what alternatives to dealing with transfer pricing existed.

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International Taxation: Problems Persist in Determining Tax Effects of Intercompany Prices