Date: 6/6/2018
Taxpayers participating in the OECD's voluntary International Compliance Assurance Program (ICAP) that have high-risk transfer pricing or permanent establishment issues may face examination, according to an IRS official.
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Dianne Mehany, a member at Caplin & Drysdale, said more taxpayers will likely be interested in the program if the assurances they receive regarding low- and medium-risk activities last longer than two years.
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Excerpt taken from the article “Risks Identified in Compliance Program May Trigger Examination” by Alexander Lewis for Tax Notes.