In an article recently published in Bloomberg BNA’s Tax Management Memorandum, Mayer Brown Tax lawyers Lewis Greenwald, Brian Kittle and Lucas Giardelli reviewed certain circumstances where taxpayers should be allowed to make corrections to their transfer pricing notwithstanding the seemingly absolute bar of Treas. Reg. Sec. 1.482-1(a)(3) and the Court of Federal Claims decision in Intersport Fashions West Inc. v. United States.
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