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A major issue surrounding transfer prices in the international arena is their effect upon the total tax burden of parent firms. The levels of income taxes and tariffs vary considerably across countries. Corporate income tax rates range from the middle teens up to 50% in some countries. This presents the possibility that transfer prices may be set in part to minimize a firm s worldwide tax bill. Establishing the reasonableness of international transfer prices is the principal defense against a charge of transfer price manipulation. Ignoring other factors bearing on the setting of transfer prices, assume that the objective is to minimize worldwide income taxes. Assume that the income tax rate of the parent is 40% and that of the foreign subsidiary is 30%. Further, the parent is the manufacturer and transfers are made to the foreign subsidiary. The total cost of the product is $100 per unit and it can be sold by the foreign subsidiary at insignificant additional cost for an amount equal to $150. Therefore, the total worldwide pretax profit to be recognized is $50. While the parent would not have unlimited f lexibility in setting the transfer price, tax minimization would call for recognizing as much of the profit as possible in the earnings of the subsidiary. This is because the subsidiary s tax rate is only 30% while the parents is 40%. Tax minimization is accomplished by setting a relatively low transfer price as illustrated in Exhibit 12.31.

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This guy had been in a hurry one day He thought, I need to back this up, so he d done it And, after being backed up like maybe three or four months ago, it was still sitting there So, this gives me a feel for the network and really how maybe the sys admins worked, because this wasn t some developer person or someone without access This was someone who could create a network share, but he obviously wasn t amazingly worried about security Robert went on: If he d been anally secure like me, he would have had a password on that share, and he maybe would have called the share something random And he would have removed it afterwards Even better, from Robert s perspective: He had a copy of his Outlook in there as well with all of his addresses and contacts.

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I copied out the file archive, Robert says I retrieved his Outlookpst file with all his email, 130 or 140 megs He logged off and spent a few hours reading the guy s email He uncovered Public announcements, pay changes, performance reviews, everything about this guy I found out quite a bit of information about him he was one of the lead sys admins on the network and he was responsible for all of the Windows servers, Robert said And I was able to gain through his box who the other sys admins were and who had a lot of access It got even better: The information within his email was extremely useful I was able to develop a list of people who would likely have access to the source code I wanted I wrote down all their names, all the details I could get.

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