IRS Preps Legal Memos on Pass-Throughs, Transfer Pricing Rules

Legal advice memos are coming from the IRS on issues concerning pass-through entities and a key standard on transfer pricing and intangible property.

The generic legal advice memoranda, or GLAMs, will deal with the use of pass-through entities “in a particular context”; hybrid entities; and the “commensurate with income” transfer-pricing standard, said Peter Blessing, associate chief counsel (international) at the IRS, speaking at a Practising Law Institute event Thursday.

Blessing didn’t provide further details on the forthcoming GLAMs and didn’t indicate when they might be issued. A GLAM lays out the IRS’s legal position on a particular tax issue ...