IRS Urged to Address Emerging Issues in Transfer Pricing Update

Tax pros want an upcoming IRS retooling of guidance on advance pricing agreements to provide flexibility for taxpayers to deal with complex new issues and offer more certainty.

A lot has changed in the world of tax since the IRS issued its last guidance in 2015—from international tax frameworks to internal IRS regimes, practitioners said. While they wait on the IRS updates, they noted a number of issues they would like to see addressed, such as the global tax deal.

Practitioners also called for more clarity in the advance pricing agreements and mutual agreement procedures. In APAs, a company and ...