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		<title>Pipe Dream # 5:  Can we recognize that not all intellectual capital is housed in the US? Or, can we take the future of our country into account in devising tax laws relating to transfer pricing?</title>
		<description><![CDATA[Departing from transfer pricing for a bit, one of my concerns has long been the future of the US economy.  With manufacturing jobs leaving the US in droves (due, at least in part, to the differences in the cost of labor), and with R&#38;D jobs in jeopardy (due to declining US educational standards and the [...]]]></description>
		<link>http://www.wrighteconomics.com/2011/09/pipe-dream-5-can-we-recognize-that-not-all-intellectual-capital-is-housed-in-the-us-or-can-we-take-the-future-of-our-country-into-account-in-devising-tax-laws-relating-to-transfer-pricing/</link>
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		<title>Pipe Dream # 4:  Can we get back to the arm’s length standard?</title>
		<description><![CDATA[The US pioneered the application of the arm’s length standard to transfer pricing (although the Germans might argue with that), and it seems to be pioneering the move away from that standard now.  It is hard to know how that happened &#8212; my own personal view is that the powers-that-be in Washington needed revenue raisers [...]]]></description>
		<link>http://www.wrighteconomics.com/2011/09/pipe-dream-4-can-we-get-back-to-the-arm%e2%80%99s-length-standard/</link>
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		<title>Pipe Dream # 3:  Can we raise the bar on the type/quality of analysis?</title>
		<description><![CDATA[Dealing with IRS, or with taxpayers, in transfer pricing audits can be very frustrating.  Today, we routinely have accountants practicing economics, economists practicing law (and, I truly love doing it!!!  Not that I should, you understand, but it is fun), and lawyers practicing both economics and accounting.  This means that the analysis is not necessarily [...]]]></description>
		<link>http://www.wrighteconomics.com/2011/09/pipe-dream-3-can-we-raise-the-bar-on-the-typequality-of-analysis/</link>
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		<title>Pipe Dream # 2:  Can we get better, less biased economic opinions?</title>
		<description><![CDATA[Closely related to my first pipe dream, I note that IRS has been hiring economic experts to help with audits.  Theoretically, this is a great idea because it should help transfer knowledge from the consulting community to the IRS field economists.  In concept, I have been, and continue to be, highly supportive of the practice.  [...]]]></description>
		<link>http://www.wrighteconomics.com/2011/08/pipe-dream-2-can-we-get-better-less-biased-economic-opinions/</link>
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		<title>Pipe Dream # 1:  Are reasonable positions still inappropriate?</title>
		<description><![CDATA[IRS Director of Transfer Pricing Operations Samuel Maruca was quoted by Tax Management’s Transfer Pricing report (June 16, 2011, p. 152), that “IRS must ‘produce some winners’ to improve its credibility in the transfer pricing arena to restore balance to a system in which both sides too often take unrealistic positions.” I know that this [...]]]></description>
		<link>http://www.wrighteconomics.com/2011/08/pipe-dream-1-are-reasonable-positions-still-inappropriate/</link>
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		<title>Choosing an Advisor – Part 3</title>
		<description><![CDATA[Selecting an advisor to meet the needs of the prior blog is relatively straight-forward.  If you are hiring for the long-haul, then you need somebody competent as well as somebody you can relate to.  Competence is extremely important here.  Transfer pricing advisors have arisen in great numbers in recent years.  Some are very capable and [...]]]></description>
		<link>http://www.wrighteconomics.com/2010/10/choosing-an-advisor-%e2%80%93-part-3/</link>
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		<title>Choosing an Advisor – Part 2</title>
		<description><![CDATA[This blog assumes that you’re looking for an advisor who can handle some, or all, of the challenges presented in the previous blog (except for the one discussed in that blog).  In this case, our recommendation is to choose an advisor who has lots of experience and knows what he is doing.  It’s not so [...]]]></description>
		<link>http://www.wrighteconomics.com/2010/10/choosing-an-advisor-%e2%80%93-part-2/</link>
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		<title>Middle Market Companies &#8211; Conclusion</title>
		<description><![CDATA[Typically, today many middle market companies take a “Wait until they catch me.  Then, I’ll worry about this” approach to transfer pricing.  Depending on what IRS does with the reorganization that it is starting, this could continue to be the cost effective approach, or it could be a very dangerous approach if these companies become [...]]]></description>
		<link>http://www.wrighteconomics.com/2010/10/middle-market-companies-conclusion/</link>
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		<title>Middle Market Companies &#8211; Documentation alternatives &#8211; Selectively document transactions</title>
		<description><![CDATA[The 80/20 rule almost always applies, i.e., 80% of the dollar amount at risk relates to 20% of the transactions.  In that case, the obvious way to manage the risk at the same time that you manage the cost of compliance is to document the 80% and ignore the rest.  This is obviously where a [...]]]></description>
		<link>http://www.wrighteconomics.com/2010/10/middle-market-companies-documentation-alternatives-selectively-document-transactions/</link>
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		<title>Middle Market Companies &#8211; Documentation alternatives &#8211; Database dump CPM</title>
		<description><![CDATA[In our experience, middle market (and some large) companies sometimes put their documentation exercise out for bid.  Then, they choose the lowest bidder who almost always prepares a database dump CPM (that is the cheapest way to document transfer prices).  This approach arguably provides penalty protection, but little else.   The CPM, for those readers who [...]]]></description>
		<link>http://www.wrighteconomics.com/2010/10/middle-market-companies-documentation-alternatives-database-dump-cpm/</link>
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