Showing posts with label Transfer. Show all posts
Showing posts with label Transfer. Show all posts

Sunday, December 3, 2017

Programming Representational State Transfer (rest)

Programming Representational State Transfer (rest)

REST (representational state transfer) is a process for getting information content from a Web site by reading a designated Web page that contains an XML (Extensible Markup Language) file that describes and includes the feasible content. For example, REST could be used by an online publisher to make syndicated content available. Periodically, the publisher would prepare and activate a Web page that included content and XML statements that described the content. Subscribers would need only to know the URL (Uniform Resource Locator) for the page where the XML file was located, read it with a Web browser, interpret the content data using the XML information, and reformat and use it appropriately (perhaps in some form of online publication).

Now question is that why doesn't the REST programming section include any code? It is largely because REST is more about a mindset rather than code, more about design than implementation.It may look simple, but there are few vital points to keep in mind while developing applications in the REST style. Think about the business problem in respect of resource manipulation rather than Application programming interface design. Enabling web services requires making data available for use by applications without knowing ahead of time exactly how that data will be used. Start by modeling the persistent resources that is to be exposed.

There must have a single, unambiguous, authoritative identity within a system in order to identify all the conceptual entities that the system exposes as resources and to assign a unique URL to each of them. In case of temporary resource you should be very careful if you plan to use them only as a temporary resource.

Publicly exposed resources should be sorted out that are immutable by the client and those are mutable. Putting and deleting should be used in appropriate manner. Proper methods should be implemented that will allow both sender and receiver to make the absolute minimum of assumptions as to the other's state.Single logical operation should not be implemented when there are multiple requests. Applications that need to be expects, accepts and returns should be properly documented. A good specification of the representational schema of both mutable and immutable resources with a formal mechanism should be there (for example, XML Schema, DTD, Schematron, or RelaxNG).

There should be a proper description and documentation of the resources that can be accessed by using a "gradual unfolding methodology" to expose data for clients. Proper linking to other related resources in every representation to enable clients to drill down for more information should be there.You should know how to use the software to setup a server that can do content negotiation, authentication, authorization, compression, caching, vacuuming and house cleaning. A proper abstractions should be there so the implementation can be carried out in a good way. If there is abstractions then it can survive the storm of change from different implementations and new technologies.

Representational State Transfer
REST Architecture

Thursday, July 27, 2017

Transfer Pricing

Transfer Pricing

By Lance Wallach


The IRS dedicates enormous resources toward dealing with taxpayer's who are involved with any form of transfer pricing. The transfer pricing provisions of IRC 482 address four general types of transactions between commonly owned or controlled parties.

1-   Use or transfer of tangible property

2-   Services

3-   Loans

4-   Use or transfer of intangible property  (especially cost sharing agreements)


Use of tangible property: When one member of a controlled group rents or leases property to another member of the group, the price paid for use of such property must equal an arm's length amount. Per Treas. Reg. 1.482-2(c )(2)(i), the arm's length amount is determined by reference to the amount that would have been charged between independent parties for use of the same or similar property under similar circumstances.


Determination of what is arm's length for fair rental value transactions:

a) Period of use

b) Location of use

c) Owner's investment in property or rent paid

d) Expenses of maintaining the property

e) Type of property

f)   Condition of property


Transfer of tangible property: When sales or transfers of tangible property are made between related parties (sales of goods), the arm's length price generally is the price that an unrelated party would pay for similar property under similar circumstances.


Determination of what is arm's length for inter-company sales: The regulations specify six methods used to determine whether an arm's length amount has been charged between members of a controlled group. Treas. Reg.1.482-3(a), states that the "best method" should be used to determine arm's length price. The IRS views the "best method" as the method that produces the most reliable results based on facts and circumstances. The IRS is well aware of the fact that many transfer pricing studies are prepared with the intention to validate year-end inter-company cost of sales regardless of whether they are arm's length just to avoid the IRC 6662 penalties. Taxpayer's would be best served if transfer pricing studies were prepared by knowledgeable experts in the field of transfer pricing.


Inter-company Services:When one member performs services for another member of a controlled group, an arm's length charge is required. This includes services such as marketing, management, technical services, or any other type of service. Such services can be provided by one party for the joint benefit of all members, or can be provided between two members of the controlled group.


Determination of what is arm's length for inter-company services: The arm's length standard for services between related parties is found in Treas. Reg. 1.482-2(b)(3) which states, " an arm's length charge for services rendered shall be the amount which was charged or would have been charged for the same or similar services in independent transactions with or between unrelated parties under similar circumstances considering all relevant facts." The arm's length charge for services between related parties will depend upon the facts related to the services provided. The pricing rules fall within three categories:

1) An arm's length charge will be based on the amount that would have been charged by an unrelated party. This generally means that the price should be based on reimbursement of cost, plus a mark-up for profit.

2) An arm's length charge may be based on only the costs incurred, provided that certain criteria are met.

3) No charge is necessary, if certain criteria are met.


The area that concerns the IRS most with these type transactions are technical services fees provided by larger U.S corporations to its foreign CFC's which are not charged. In regards to smaller cases, the IRS typically examines management fees in detail to ensure they are arm's length.


Inter-company Loans:In the context of IRC 482, most of the areas of conflict in this area revolve around interest. When loans are made between members of a controlled group, interest rates charged do not always meet the required arm's length standard.


Determination of what is arm's length for inter-company loans:The arm's length standard for loans between related parties is found in Treas. Reg. 1.482-2(a)(2) which states that " an arm's length rate of interest shall be a rate of interest which was charged, or would have been charged, at the time the indebtedness arose, in independent transactions with or between unrelated parties under similar circumstances."


Factors that are listed in Treas. Reg. 1.482-2(a)(2) that should be considered in determining arm's length interest are:

a) The principle amount and duration of the loan.

b) The security involved

c) The credit standing of the borrower

d) The prevailing interest rate where the loan was made


The regulations provide further guidance in the following areas:

a) Safe harbor rules

b) Ordering rules

c) Determination of bona fide indebtedness

d) Period for which interest is charged


Transfers of intangible properties: When transfers of intangible property are made between controlled parties, the arm's length price is often difficult to determine, in part because the property's value derives from intellectual capital such as ideas, the outcome of research and development or creation of software.


Determination of what is arm's length for transfer of intangible property:The regulations specify four methods to determine whether an arm's length amount has been charged between the members of a controlled group with respect to the transfer or use of intangible property. Treas.Reg.1.482-4(a) states that the "best method" should be used to determine the arm's length price between related parties. Controlled parties may enter into a qualified cost sharing arrangements to share costs related to developing intangibles. They may also contribute existing intangibles for use in further development or for use in developing new and distinct intangibles.


The following general rules of Treas.Reg.1.482-7(a) and (b) apply to qualified cost sharing arrangements:

a) Two or more controlled participants agree to share the costs of developing intangibles.

b) Costs are shared based on each participant's share of reasonably anticipated benefits from the intangibles to be developed.

c) A "buy-in" must be paid to the participant that contributes pre-existing intangible property to the qualified cost sharing arrangement.


As with transfer pricing reports, cost sharing agreements should be prepared by qualified experts who are knowledgeable in this area. If examined by the IRS, the cost sharing agreement will be reviewed in detail. For further insight refer to the Coordinated Issue Paper utilized as a guideline for the IRS personnel dated June 5th 2009.


Lance Wallach speaks and writes extensively about VEBAs, retirement plans, and tax reduction strategies. He speaks at more than 70 conventions annually writes for 50 publications, and was the National Society of Accountants Speakers of the Years. Contact him at 516.938.5007 or visit

The information provided herein is not intended as legal, accounting, financial or any other type pf advice for any specific individual or other entity. You should contact an appropriate professional for any such advice.

Lance Wallach, captive insurance and Section 79 plan expert, is the nation's leading authority on resolving IRS tax problems for individuals and businesses.

Mr. Wallach, National Society of Accountants' Speaker of the Year, is a member of the AICPA faculty of teaching professionals and he is a renowned national expert witness in many 419, 412i, and financial abuse cases. To date his side has never lost a case.

Mr. Wallach is often a featured speaker at national conventions for CPAs, attorneys, and business owners and other entrepreneurs, and has over 30 years experience helping people get the most possible money back from the IRS.  He can be contacted at 516-938-5007 or, or visit or for more information.

Lance Wallach is the author of many best selling accounting, taxation, and financial books, including:


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