Compaq Computer Corporation and Subsidiaries - Page 14




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          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.                          







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