In a new International Practice Unit (IPU), the IRS provides audit tips to its examiners on a taxpayer’s affirmative use of Internal Revenue Code Section 482, “Allocation of Income and Deductions.” That section of tax law gives the IRS the authority to make adjustments between or among members of a “controlled group,” if a controlled taxpayer hasn’t reported its true taxable income. (more…)
In a new International Practice Unit (IPU), the IRS charted audit steps its examiners should follow in reviewing the transfer pricing documentation of U.S. taxpayers that transfer and provide tangible property, intangible property, and service to foreign affiliates in exchange for payments (that is, outbound transactions). (more…)
A group of multinational enterprises (MNEs) in the United States and abroad has asked the U.S. Treasury to “significantly change” certain transfer pricing guidance arising from the Organisation for Economic Co-operation and Development’s (OECD’s) base erosion and profit shifting (BEPS) project.
By Guest Blogger: Rob Trammell, ASL Principal
The IRS recently released a “Roadmap for Transfer Pricing Auditors.” This roadmap lays out IRS policy related to transfer pricing issues, and provides auditors with tools and detailed procedures for how to work a case.