Transfer pricing Archives - John R. Dundon II, Enrolled Agent
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Transfer pricing

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...

The IRS Advance Pricing Agreement (APA) Program, concerned exclusively with reaching pre-filing agreements with taxpayers on transfer pricing, will shift from the office of IRS Chief Counsel to an office under the Transfer Pricing Director in the Large Business & International division’s international operation. In...

IRS Commissioner Douglas Shulman said the agency would focus more of its efforts on closely scrutinizing transfer pricing arrangements that allow U.S. companies to avoid taxes on income earned abroad, as well as conduct joint audits with tax authorities in other countries. Shulman said the IRS...

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