Entries by Manager

Recent Developments in Transfer Pricing

The IRS is currently examining new procedures and policies regarding transfer pricing audits. Recently, the IRS developed a “Transfer Pricing Practice” within its Large and Mid-Size Business (LMSB) operating division, and last August, the IRS realigned its Large Business & International (LB&I) operating division to handle international tax matters more effectively. The Service intends to […]

IRS Reorganizes Transfer Pricing Compliance Programs and International Coordination

On July 27, 2011, the IRS announced that it is taking additional steps in its continuing efforts to improve the agency’s international operations. First, the IRS Advance Pricing Agreement (APA) Program, concerned exclusively with reaching pre-filing agreements with taxpayers on transfer pricing, will shift from the office of IRS Chief Counsel to an office under […]