Provides an in-depth coverage of inter-company pricing rules, including inter-company sales, loans, services, leasing, and transfers of intangibles. Discusses inter-company sales cases, as well as the treatment of inter-company loans under the imputed interest and below market loan provisions. Examines advance pricing agreements and relevant treaty provisions. Prerequisite(s): TA 321. Cross-listed with and equivalent to the following course. (Note: no academic credit is awarded for retaking equivalent course.): LLM 350D.