Skip to main content

  • AddRemove
  • Build a Report 
Past Event
9 February 2017

Speakers

  • William A. Schmalzl
    T +1 312 701 7225
  • May Y. Chow
    Associate
    T +1 312 701 8802
Webinar

The IRS Approach to Transfer Pricing Audits: A Look at the TIGTA Report

Taxpayers with international operations should anticipate that transfer pricing issues will be a major focus of any IRS audit. IRS management has reported that transfer pricing issues account for approximately 46 percent of the entire inventory of international issues and 71 percent of the potential dollar adjustments.

The Treasury Inspector General for Tax Administration (TIGTA) recently released a report, Barriers Exist to Properly Evaluating Transfer Pricing Issues, analyzing the performance of the IRS with respect to transfer pricing issues. The report examines the way agents approach audits, the relationship of the length of the audit to its final outcome and the resolutions at Appeals. While the IRS disagrees with many of the report’s conclusions, TIGTA’s analysis and the IRS's response provide insights into how agents auditing your return and Appeals Officers will approach your transfer pricing structure.

Please join May Chow and Bill Schmalzl as they discuss the TIGTA report from the perspective of how TIGTA’s observations might impact the examination and resolution of transfer pricing issues. Topics will include:

  • How LB&I views and applies the Transfer Pricing Roadmap
  • Bottlenecks in the IRS examination process
  • Implications of the report on the IRS’s planned shift to campaigns
  • The impact on the consideration of transfer pricing issues at Appeals


CLE is not available when viewing a recording of this program. In order to receive credit you must have attended the live webinar program.

 

The Build a Report feature requires the use of cookies to function properly. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently. If you do not accept cookies, this function will not work. For more information please see our Privacy Policy

You have no pages selected. Please select pages to email then resubmit.