Bold Shift In IRS Approach To Transfer Pricing

Law360, New York (March 14, 2014, 12:48 PM EDT) -- U.S. taxpayers should prepare for major changes in IRS transfer-pricing audits. New procedures, sharpened objectives, accelerated taxpayer decision points and revised resolution opportunities will result from a confluence of just-issued IRS guidance.

All will require refined handling of audits and sophisticated analysis of strategic options. The IRS seeks to markedly alter the dynamics and outcomes of transfer-pricing audits, and taxpayers will need to plan and react accordingly.

The key IRS documents are the "Transfer Pricing Audit Road Map" (available on IRS.gov) released on Feb. 14, 2014,...
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