The IRS has a separate team to evaluate transfer pricing transactions and cross-border business dealings for international businesses here in San Diego. If you are conducting cross-border transactions, or have multiple companies and transfer goods, services, or intangible assets between these affiliated companies you need the guidance and services of Allen Barron. Our comprehensive international and domestic tax, accounting, legal and business advisory services inform and increase the effectiveness and profitability of our international clients.
The IRS announced an new policy for identifying and selecting businesses for an IRS audit in January of this year. The “Large Business and International Division” (LB&I) will target issue-focused examinations. The “transfer pricing campaign” within the IRS LB&I will focus on mid-market, multinational businesses. The IRS has set aside specific internal resources supported by IRS systems and analysis tools. These IRS revenue officers or agents have been specifically trained to identify and investigate transfer pricing issues and “inbound distributors.” IRS agents have received comprehensive training to prepare them for IRS audits of US inbound distributors of foreign goods and services. Transfer pricing and “incurred losses or small profits on US returns” which are not in balance with like business models here in the US and abroad will trigger intense investigation and in-depth IRS audits.
The core issue is the financial and tax advantages gained by conducting these transactions in a manner that is not commensurate with an “arm’s-length” transaction.
Allen Barron is uniquely positioned to guide you through the process of providing the IRS with your own transfer pricing or inbound distributorship strategy which documents and informs the IRS of all such relationships and transactions. Our expert international tax attorneys and legal team work together with our accounting and business advisory personnel to craft a well-informed strategy to guide you through these perilous waters.
The IRS has a separate team to evaluate transfer pricing transactions and inbound distributorships for IRS audit potential. It is a central focus of the IRS for 2017 and beyond. Protect yourself and your business and call 866-631-3470 for a free consultation today.
