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IRS Examinations: Enhanced Focus and Rigor

Deloitte Dbriefs | Transfer Pricing

Start Date and Time

April 10, 2013 2:00 PM

End date and time

April 10, 2013 3:00 PM

Time zone:

(GMT-05:00) Eastern Time (US & Canada)

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Host: Mark Nehoray, Partner - Deloitte Tax LLP
1 Intermediate CPE Credit: Taxes 

After reorganizing the IRS Large Business & International division in 2012, the IRS is again focusing on transfer pricing. What should you know? We'll discuss:

  • An overview of the revamped IRS operations, including Advance Pricing and Mutual Agreement Program (APMA) and the Transfer Pricing Practice (TPP).
  • Issues with inbound transfer pricing examinations, including a distributor risk-return continuum, marketing and research intangibles, and trademarks.
  • Recent transfer pricing documentation information document requests (IDRs) and penalties.
  • Practical examination considerations, including cycle time and IRS focus on historic weak spots, as well as documentation challenges.

Learn the latest challenges and opportunities associated with transfer pricing tax examinations in the U.S.

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Please note: CPE Credit is not available for viewing archived programs.

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