국제이전가격조작(International Transfer Pricing)에 관한 연구 : 최근 미세법 제482조의 개정논의와 그 영향을 중심으로 With Focusing on the Amendment of IRC Section 482 and It's Impacts on the Korean Firm's Foreign Subsidiaries in the U.S.A. = A Study on the International Transfer Pricing

다국어 초록 (Multilingual Abstract)

Trassfer pricing is the most significant international compliance issue currently facing the U.S. government, foreign govemment and business firms engaged in the international trade. By putting a more empasis on the Section 482 of Internal Revenue Code, U.S. tax authorities are more empowered to investigate and levy taxes on tax evasion of foreign firms in the U.S.A. by using an intracorporate transfer pricing.
The purpose of this study is to; 1) analye the nature of interantional transfer pricing by using literature survey, 2) the revised amendments of IRC Section 482, and evaluate it's possible impacts on the Korean firm's foreign subsidiaries in the U.S.A, 3) and consider the efficient countermeasures of Korean firms by employing a case study.