IRS officials discuss transfer pricing pilot cases, joint audits, and taxpayer initiated adjustments

Tax Insights ()

On December 16, 2011, at the 24th Annual GW-IRS Institute on Current Issues in International Taxation (co-sponsored by the Internal Revenue Service and George Washington University), a panel of officials from the Internal Revenue Service ("IRS") discussed the LB&I realignment, including the transfer pricing pilot program, transfer pricing joint audits, and the consideration of requests for competent authority ("CA") assistance in cases involving taxpayer-initiated transfer pricing adjustments. Mike Danilack, IRS Deputy Commissioner (International), explained that the LB&I realignment is an integrated international program in which international practice networks are being developed to form collaborative teams. The goal is to elevate the IRS's performance through sharing expertise through effective use and management of data collected from taxpayers, sharing expertise through collaboration, and involving the appropriate IRS personnel early in the case development process to efficiently and effectively manage cases. Mr. Danilack explained that the LB&I realignment is not intended to shift authority from examiners on transfer pricing cases, so audits should not be affected in that respect.