Graduation Year

Fall 2010

Document Type

Open Access Senior Thesis

Degree Name

Bachelor of Arts



Reader 1

James Taylor


The current problems and possible solutions surrounding United States transfer pricing regulations are discussed and studied. The schemes large multinational companies are implementing to legally evade taxes are uncovered as the financial effects to the United States Treasury and government are becoming material. The benefits for these schemes are financially advantageous for corporations as they are able to report larger profits and higher returns for investors. But this is being done at the expense of our government. Corporations are finding ways to escape the high U.S. corporate tax rate and lower their global tax liabilities by allocating income to lower tax jurisdictions. Tax havens like Ireland or Bermuda are popular to have subsidiaries which hold a corporations intangible property.

Five United States Tax Court cases concerning transfer pricing are studied and the outcomes are analyzed. The current problems studied from these cases are, shipping intangible property, valuing intangible property, the arm’s length standard. The possible solutions to these currents problems are by no means easy to solve and no one revision can relieve all the problems. The arm’s length standard is the corner stone to the current problems and if the government can find a way to better enforce the standard or replace it, it will be a large step in the right direction.