IRS Audits of Intercompany Transactions Build Steam (Podcast)

The IRS is winning more cases in the US Tax Court over companies’ valuation of intangible assets, such as patents and trademarks, through transfer pricing.

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The wins have caught the attention of companies and practitioners as they mull the growing risks of transfer pricing, which governs transactions between related companies that are part of the same multinational group.

Disputes between the IRS and companies such as Coca-Cola and 3M have showcased the agency’s newfound ability to audit their positions ...