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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...
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