We use cookies on this site to enable your digital experience. By continuing to use this site, you are agreeing to our cookie policy. close

Analysis

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...
To view the full article, register now.
Law360 Pro Say Podcast
Check out Law360's new podcast, Pro Say, which offers a weekly recap of both the biggest stories and hidden gems from the world of law.