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The Tax Act Changes the Game for Transfer Pricing

USA - February 5 2018 The “Tax Cuts and JOBS Act” (the “Tax Act”), signed into law by President Donald Trump on December 22, 2017, fundamentally changes the US...

C. Cabell Chinnis, Scott M. Stewart, William G. McGarrity, Kenneth Klein, Gary Wilcox, Thomas L. Kittle-Kamp, Brian W. Kittle, Jason M. Osborn, Lucas Giardelli.


New IRS Transfer Pricing Directives

USA - January 18 2018 On January 12, 2018, the IRS Large Business and International ("LB&I") Division released a set of "Directives" regarding new transfer pricing...

Brendan J. Sponheimer, Larry R. Langdon, Brian W. Kittle.


IRS Appeals Procedures Continue to Evolve

USA - October 17 2016 In October 2016, the US Internal Revenue Service again changed how its Office of Appeals interacts with taxpayers and exam teams. On top...

C. Cabell Chinnis, Anthony D. Pastore, Paul DiSangro.


Supreme Court issues a taxpayer favorable opinion in United States v. Clarke

USA - June 19 2014 The Supreme Court held on June 19, 2014, that taxpayers are entitled to examine IRS agents in a summons-enforcement proceeding where taxpayers...

Geoffrey M. Collins, Brian W. Kittle.


Internal Revenue Service releases directive on information document request enforcement process

USA - November 6 2013 On November 4, 2013, the Internal Revenue Service (IRS) released its highly-anticipated Large Business and International Directive on Information...

Larry R. Langdon, Brian W. Kittle, Brian C. Power.