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Transfer Pricing Report

Multinationals Face Gap in IRS Transfer Pricing Valuation Rules

Sept. 18, 2018, 9:35 PM

Multinationals may not have seen the end of a rule that gives the IRS greater authority to decide how to value intercompany transfers of valuable assets.

Temporary regulations that let the Internal Revenue Service broadly apply the “aggregation” method to value a multinational’s intercompany transactions expired Sept. 14. But the Service could still apply those concepts or make the regulations final because a version of those concepts appears in the 2017 tax law (Pub. L. No. 115-97) and in previous proposed regulations.

“I wouldn’t pop the champagne yet,” said John Warner, shareholder at Buchanan Ingersoll & Rooney PC in...

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