In this CLE course you will learn the statutory and regulatory history of U.S. Transfer Pricing, and then we will analyze the concepts that inform both U.S. transfer pricing between taxpayers and the Internal Revenue Service, as well as transfer pricing between the Internal Revenue Service and the governments with whom the U.S. has entered tax treaties. These concepts include but are not limited to: control, the arm’s length standard, formulary apportionment, the best method rule, comparability, and reliability. Finally, we will learn the regulatory methods to price controlled transactions involving tangible property. The regulatory methods to price intangibles is the subject of the next course, International Taxation: Introduction to U.S. Transfer Pricing, Part II.