Provides an in-depth coverage of intercompany pricing rules, including intercompany sales, loans, services, leasing, and transfers of intangibles. Discussion of intercompany sales cases, as well as the treatment of intercompany loans under the imputed interest and below market loan provisions. Examination of advance pricing agreements and relevant treaty provisions. Cross-listed with and equivalent to TA 350D. (JD students seeking to enroll must obtain the approval of the program director.) Prerequisite: LLM 321.