On July 23, 2025, the Internal Revenue Service ("IRS") issued interim guidance announcing changes to the Large Business & International Division ("LB&I") audit procedures (see the IRS's memorandum, here). The changes aim to...more
On May 26, 2025, the Mexican Tax Administration Service (SAT) reported a 367% increase in tax revenue from large multinationals audits resulting from enforcing Mexico's transfer pricing rules. From 2019 through 2024, the...more