Outside Publication

Timing Is Crucial When Seeking Transfer Pricing Penalty Relief, Bloomberg Law

2024年09月09日

In a Bloomberg column, partner Thomas Linguanti and associate Drew Cummings note that penalties in transfer pricing audits by the Internal Revenue Service (IRS) are on the rise. Companies should consider their options for seeking relief, including parallel dispute resolution tracks through the IRS Appeals office or the Mutual Agreement Procedure (MAP), especially when US treaty partners do not accept penalties in MAP negotiations.

View the full Bloomberg Law article >>
Subscription may be required