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Tax Articles

Coca Cola’s Recent IRS Statutory Notice of Deficiency – a Tipping Point in International Transfer Pricing Enforcement

In Coca Cola’s SEC 8-K filing last week we learned that the IRS issued a $3.3 Billion statutory notice of deficiency against the company as the result of a 5 year long transfer pricing audit covering tax years 2007-09. This is very BIG when it comes to enforcement of IRC 482 – Allocation of Income and Expenses Among Taxpayers because of…


General ITIN References & Contact Information Including IRS Pub 1915 & IRS Rev Proc 2006-10

Aside from this tax blog the following are the most useful resources for researching Individual Taxpayer Identification Number (ITIN) application processing. IRS Publication 1915 General ITIN Information page Update to the Instructions for Form W-7 and ITIN Processing Time IRS Rev Proc 2006-10 IRS Form W-7 IRS Form W-7 Instructions If you need assistance in…


Brian Dooley’s Tax Research Tool

I was reminded late last night while knee deep in yet another complex file that one of my many blessings has been the opportunity to connect on several distinct levels with many different people all over this great planet. From introspective artists in San Francisco to international bankers in Moscow, coffee plantation owners in El…