Volume 5 Number 5    |    Read Article

By Michael Peggs

For management of a U.S. subsidiary of a foreign parent, the process by which the I.R.S. conducts an examination of a tax return creates a heightened stress level. It begins with the arrival of an information document request (“I.D.R.”) for transfer pricing documentation, which often comes as a surprise to a company. Typically, two or three years have passed since the close of the year under examination and little is recalled about transactions. From there, the expressed positions of I.R.S. examiners and management often are at odds. Drawing on many years of experience in defending intercompany transfer pricing policies, Michael Peggs takes a step back from the fray to examine how opposing, pre-conceived notions on both sides combine with the Semmelweis Reflex to exacerbate what should be a straightforward tax examination.   See more →