The IRS has designated transfer pricing as a key focus of its international compliance initiatives. Several trends have contributed to the IRS’s decision to target transfer pricing. As a consequence of these trends, the IRS has determined that it is the right time for a renewed emphasis on transfer pricing enforcement.
Our article outlines some of the actions that the IRS has already taken, and what these actions mean for multinational taxpayers. It discusses some steps that taxpayers can take to meet the challenge posed by the IRS’s enforcement initiatives.