December 11, 2012


Mark Martin, Partner, McDermott Will & Emery LLP
Mark Horowitz, Associate, McDermott Will & Emery LLP

This webcast provided insight on the Internal Revenue Service in relation to transfer pricing.  Recently, the IRS has fallen drastically behind foreign tax authorities in proposing transfer pricing adjustments. There has been material funding for U.S. cross-border tax base protection, as Congress has been critical of the planning methodologies of multinational companies.

During this one-hour webcast we discussed:

  • The creation of the “Transfer Pricing Practice of the International Revenue Service’s Large Business and International division
  • What professionals can expect in transfer pricing examinations, dispute resolution substance and efficiency, and related matters
  • The relationship to potential tax reform after the 2012 Presidential election

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