As state revenue agencies train their auditors in traditional IRC §482 transfer-pricing methodologies or outsource transfer-pricing audits to third-party specialists, a recent initiative by the Indiana Department of Revenue...more
The IRS has announced its intention to audit wealthy taxpayers and their associated business entities starting in mid-July. This LawFlash alerts sports owners, athletes, entertainers, and others in these industries to the...more
At a recent American Bar Association Section of Taxation meeting in Washington, DC, Deputy Chief of the IRS Office of Appeals Andrew Keyso, Jr. discussed the extension of a pilot program that provides for the potential...more
A recent policy statement from the US Department of Treasury provides important information for taxpayers navigating US tax reform and alters the existing tax regulatory landscape in a few meaningful ways. Taxpayers should be...more
July 24, 2018, marked a significant, although potentially short-lived, victory for the Internal Revenue Service (IRS), as a panel of the US Court of Appeals for the Ninth Circuit reversed by 2 votes to 1, the full US Tax...more
Serving as a roadmap for how the Internal Revenue Service intends to conduct transfer pricing examinations, the recently released Transfer Pricing Examination Process guide provides a set of processes and practices for the...more