IRS creating efficiencies in transfer pricing enforcement and compliance

Tax Insights ()

On December 15, 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") and the United States Department of Treasury discussed how they intend to create a more efficient process for transfer pricing enforcement and compliance. In 2010, the Large and Mid-Sized Business division of the IRS realigned into the Large Business and International ("LB&I") division. As part of this realignment, the IRS created a transfer pricing practice within LB&I and is in the process of combining the Advance Pricing Agreement ("APA") Program and the Tax Treaty Office staff who handle Mutual Agreement Procedure ("MAP") transfer pricing cases into one office in LB&I, called the Advance Pricing and Mutual Agreement ("APMA") program. The panel provided the following organizational charts of LB&I's international functions in 2010 and the planned functions in 2012 to demonstrate the realignment.