Two international practice networks have launched within the transfer pricing operation of the IRS. Transfer Pricing Director Samuel Maruca has announced the formation of two new International Practice Networks within the IRS focusing on in-bound and outbound income shifting in order to bring a higher level of professionalism within the service. This is part of his continuing effort to create an equivalent structure on par with that of the best run professional firms.
The reorganization aims to bring all areas of transfer pricing enforcement into one office. In his statement’s Maruca acknowledged the IRS’ recent losses in cases involving key issues, which as driven in part his goal of enhancing the technical expertise and advocacy skills of its personnel.
One goal of the new IPNs is to coordinate more closely with treaty partners, extending to joint audits, exchange of information and joint fact development, with the possible establishment of safe harbor agreements.
What do the new current restructuring initiatives mean to taxpayers? Maruca does not expect much change, except that experts handling cases going forward will have more responsibility.
This was originally published on Checkpoint.