By Michael Peggs ( July 23, 2018, 2:57 PM EDT) -- The arrival of an information document request, or IDR, for transfer pricing documentation often comes as a surprise to a company. Typically, two or three years have passed since the year under examination and little is recalled about transactions reported on a Form 5472, which reports transactions with controlled taxpayers such as a foreign parent or a related supplier outside the United States. Yet, in today's post-base erosion and profit shifting world, international examinations with a focus on transfer pricing are commonplace....
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