IRS Backs New Transfer Pricing Rules Despite Tax Deal Rebuke

The IRS is still encouraging taxpayers to use the simplified transfer pricing method laid out in the global tax treaty, even after the Trump administration disavowed the deal.

IRS guidance published last month remains in effect, allowing companies to choose whether to apply the transfer pricing framework, known as Amount B. That notice included a great deal of flexibility to encourage widespread adoption.

The flexibility should encourage taxpayers to adopt the method early if it works in their situation—even if they don’t know what other jurisdictions are going to do, Brad McCormack, senior technical reviewer at IRS Associate Chief Counsel ...