The Internal Revenue Service announced a new initiative last October, called the Large Foreign-Owned Corporations Transfer Pricing Initiative, which involved sending “compliance alerts” to about 150 subsidiaries of large foreign corporations—with that number increasing to 180 by mid-November. The alert advised these companies to re-evaluate their tax obligations and promoted self-correction of their filings.
There is confusion by many recipients of the alert about what obligations require compliance and how to accomplish this. In an article originally published in Bloomberg Tax, Grant Thornton National Technical Director Steven Wrappe writes in detail about what this new IRS transfer compliance alert is, when it is used, what alternatives are available and the consequences of those choices.
Read the Bloomberg Tax article here.
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