The resources the IRS has devoted to transfer pricing enforcement has grown recently due to a number of factors. An organizational change to oversight more than a decade ago has laid the groundwork for the IRS to successfully prosecute some recent high-profile transfer pricing cases.
Steven Wrappe, Grant Thornton National Technical Leader for Transfer Pricing, discusses the impact of this increased level of IRS scrutiny on transfer pricing enforcement in an article for Bloomberg Tax called “Surveying 2024 US Transfer Pricing Enforcement Trends.” Wrappe reviews the establishment of the Transfer Pricing Practice within its Large Business and International division in 2012 and how this sparked an initiative aimed at enforcing compliance. Additional funding from the Inflation Reduction Act allowed added personnel to the initiative.
Wrappe ends the article by calling for multinationals to evaluate their compliance profile and update documentation for operations changes or changed expectations in light of recent IRS wins. Read the Bloomberg Tax article here.
Contact:
Content disclaimer
This content provides information and comments on current issues and developments from Grant Thornton Advisors LLC and Grant Thornton LLP. It is not a comprehensive analysis of the subject matter covered. It is not, and should not be construed as, accounting, legal, tax, or professional advice provided by Grant Thornton Advisors LLC and Grant Thornton LLP. All relevant facts and circumstances, including the pertinent authoritative literature, need to be considered to arrive at conclusions that comply with matters addressed in this content.
For additional information on topics covered in this content, contact a Grant Thornton professional.
Grant Thornton LLP and Grant Thornton Advisors LLC (and their respective subsidiary entities) practice as an alternative practice structure in accordance with the AICPA Code of Professional Conduct and applicable law, regulations and professional standards. Grant Thornton LLP is a licensed independent CPA firm that provides attest services to its clients, and Grant Thornton Advisors LLC and its subsidiary entities provide tax and business consulting services to their clients. Grant Thornton Advisors LLC and its subsidiary entities are not licensed CPA firms.
Tax professional standards statement
This content supports Grant Thornton Advisors LLC’s marketing of professional services and is not written tax advice directed at the particular facts and circumstances of any person. It is not, and should not be construed as, accounting, legal, tax, or professional advice provided by Grant Thornton Advisors LLC. If you are interested in the topics presented herein, we encourage you to contact a Grant Thornton Advisors LLC tax professional. Nothing herein shall be construed as imposing a limitation on any person from disclosing the tax treatment or tax structure of any matter addressed herein.
The information contained herein is general in nature and is based on authorities that are subject to change. It is not, and should not be construed as, accounting, legal, tax, or professional advice provided by Grant Thornton Advisors LLC. This material may not be applicable to, or suitable for, the reader’s specific circumstances or needs and may require consideration of tax and nontax factors not described herein. Contact a Grant Thornton Advisors LLC tax professional prior to taking any action based upon this information. Changes in tax laws or other factors could affect, on a prospective or retroactive basis, the information contained herein; Grant Thornton Advisors LLC assumes no obligation to inform the reader of any such changes. All references to “Section,” “Sec.,” or “§” refer to the Internal Revenue Code of 1986, as amended.
Grant Thornton Advisors LLC and its subsidiary entities are not licensed CPA firms.
Our fresh thinking
No Results Found. Please search again using different keywords and/or filters.