Tax Reform Seen Prompting Few Transfer Pricing Settlements

Law360 (February 23, 2018, 8:11 PM EST) -- The new U.S. tax on deemed repatriated offshore earnings could encourage the Internal Revenue Service to settle some pending transfer pricing cases, but it won't cause the agency to abandon most of those assessments, practitioners told Law360.

The U.S. Tax Cuts and Jobs Act, P.L. 115-97, lowered the corporate rate from 35 percent to 21 percent and introduced measures that move the U.S. in the direction of a territorial tax regime. As part of the transition to the new system, new Internal Revenue Code § 965 imposes a one-time tax on offshore earnings at dual rates — 15.5 percent for cash...

Stay ahead of the curve

In the legal profession, information is the key to success. You have to know what’s happening with clients, competitors, practice areas, and industries. Law360 provides the intelligence you need to remain an expert and beat the competition.

  • Access to case data within articles (numbers, filings, courts, nature of suit, and more.)
  • Access to attached documents such as briefs, petitions, complaints, decisions, motions, etc.
  • Create custom alerts for specific article and case topics and so much more!


Hello! I'm Law360's automated support bot.

How can I help you today?

For example, you can type:
  • I forgot my password
  • I took a free trial but didn't get a verification email
  • How do I sign up for a newsletter?
Ask a question!