The Transfer Pricing Law Review
Ed Froelich and Jessica Stern authored an article for The Transfer Pricing Law Review that provides a high-level overview of the principal transfer pricing rules in the United States.
"Cross-border transactions in general will remain a high priority for scrutiny and tax enforcement in the United States," the authors wrote. "Transfer pricing is probably the highest-priority issue within this general category of transactions. The IRS has already identified one type of transfer pricing transaction (inbound distributors) as a formal campaign audit issue but has also indicated that transfer pricing generally is a top enforcement issue."
Read the full article.