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Audits Internal Revenue Service Transfer Pricing

Morgan Lewis

Evolving Transfer Pricing Controversy: Divergent Paths in the United States and Ireland

Morgan Lewis on

Transfer pricing enforcement is undergoing significant changes in both the United States and Ireland, with the two jurisdictions actively moving in different directions. While the United States is experiencing internal...more

McDermott Will & Schulte

IRS Acknowledges Limitations on Use of Outside Contractors in Audits

Several years ago, it came to light that the Internal Revenue Service (IRS) had hired a law firm to assist with transfer pricing matters in an ongoing audit of a large corporate taxpayer. Contemporaneous with that hiring, the...more

McDermott Will & Schulte

IRS Announces More LB&I Campaigns!

The Internal Revenue Service (IRS) Large Business and International (LB&I) Division continues to churn out new audit “campaigns.” For our prior coverage... The most recent set of campaigns were announced on April 16, 2019,...more

Morgan Lewis

Transfer Pricing Audits Under the New Transfer Pricing Examination Process

Morgan Lewis on

Serving as a roadmap for how the Internal Revenue Service intends to conduct transfer pricing examinations, the recently released Transfer Pricing Examination Process guide provides a set of processes and practices for the...more

Dickinson Wright

Inter-Company Pricing Practices of Taxpayers with Foreign Affiliates

Dickinson Wright on

The Internal Revenue Service has increased its scrutiny of inter-company pricing practices of taxpayers with foreign affiliates and has provided agents conducting audits with standard language requesting information about...more

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