International Transfer Pricing for Goods and Intangible Asset Licenses in a Decentralized Multinational Corporation: Review and Extensions

We review and extend the core literature on international transfer price manipulation to avoid or evade taxes. Under negotiated transfer pricing with a viable bargaining structure, including performance evaluation disconnected from the transfer price, divisions voluntarily exchange accurate information to obtain firm-wide optimality, a result not dependent on restraint from exercising internal market power. For intangible licenses, a larger optimal profit shift for a given tax rate change strengthens incentives for transfer pricing abuse. In practice, an intangible's arm's length range is viewed as a guideline, a context where incentives for abuse materialize. Transfer pricing for intangibles obliges greater tax authority scrutiny.

From Concrete to Abstract: Teaching for Transfer of Learning when Using Manipulatives

One of the most important uses of manipulatives in a classroom is to aid a learner to make connection from tangible concrete object to its abstraction. In this paper we discuss how teacher educators can foster deeper understanding of how manipulatives facilitate student learning of math concepts by emphasizing the connection between concrete objects and math symbolization with, preservice elementary teachers, the future implementers of knowledge. We provide an example and a model, with specific steps of how teacher educators can effectively demonstrate connections between concrete objects and abstract math concepts.