- 14 - semiannually by the Compaq U.S. tax department and were based on Compaq U.S. standard manufacturing costs that Compaq U.S. used as a benchmark for purchasing PCA's from unrelated subcontractors. The prices did not, however, include compensation for overtime, rework performed, changes in material prices, changes in the delivery schedule, material cancellation costs, inventory shrinkage, production scrap, setup charges, or obsolete inventory. Specifically, in 1991 and 1992, the transfer prices for Compaq Asia PCA's were set using a cost-plus formula, pursuant to section 1.482-2A(e)(1), Income Tax Regs. The formula was Compaq U.S. labor and overhead costs minus Compaq U.S. overhead costs that would continue to be incurred by Compaq U.S. despite manufacture of PCA's at Compaq Asia (Compaq U.S. fixed overhead costs) multiplied by 1.15 plus Compaq U.S. material costs. Compaq Asia costs were not used as part of the transfer price analysis. In 1992, the formula was amended, and Compaq Asia material, labor, and overhead costs were multiplied by 1.3, plus a total location savings times .3. The total location savings was calculated by subtracting Compaq Asia material, labor, and overhead costs and Compaq U.S. fixed overhead costs from Compaq U.S. standard material, labor, and overhead costs.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011