IRS to Release Pair of Rules on Valuing Intercompany Transfers

The IRS aims to release final rules that describe how U.S. multinationals should value certain intercompany transactions by the end of this year, an agency official said.

The rules would finalize a previously expired set of regulations on valuing intercompany transfers under tax code Section 482, which deals with transfer pricing—the way companies value the assets they transfer between related parties.

The IRS is also working to update other rules under Section 482 to better align with the 2017 tax law, which will likely come later, Christopher Bello, branch chief at the IRS Office of Chief Counsel (International), said ...