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BNA Quotes Peter Barnes: Why Are Taxpayers Winning on Transfer Pricing in IRS Appeals?

December 2, 2016, Bloomberg BNA

A recent report from the Department of Treasury's inspector general highlights the difficulty IRS examiners are having sustaining tax adjustments through the internal appeals process. It's a problem tax professionals have long felt indicates either poor issue selection or overreach by examiners—although the figures in the report still raised some eyebrows. Peter A. Barnes, a senior lecturer at Duke University and of counsel at Caplin & Drysdale, Chartered, noted that focusing on audit adjustments may be misguided.

“In a perfect world, there would be zero adjustments, because taxpayers would have appropriate, defensible transfer prices in place and the results would be reported on the returns,” Barnes said in a Nov. 30 e-mail to Bloomberg BNA. “Both taxpayers and the government need to focus on good guidance, good compliance practices, safe harbors and other ways to reduce the number of adjustments.”

To view the full article, please visit Bloomberg BNA's website (subscription required).

Excerpt taken from the article “Why Are Taxpayers Winning on Transfer Pricing in IRS Appeals?” by Alex M. Parker for Bloomberg BNA.


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