The IRS is laying the groundwork for more aggressive and contentious transfer pricing controversies, recently revealing that it will more actively consider applying the economic substance doctrine and related penalties in those cases. It is unclear how the IRS would apply the doctrine to otherwise economically meaningful related party arrangements, but the IRS’s shot across the bow should be taken seriously, and the new approach will likely soon be made manifest at the examination stage.
Read publication We are pleased to enclose the June issue of Tax News and Developments, a publication of Baker McKenzie’s North America Tax Practice Group. This month’s edition features Proposed Regulations on Deductibility of Certain Fines and Penalties and Related Information Reporting Retirement Relief Provisions Accessible to More Taxpayers and…