Related party pricing is both a domestic tax issue and an international cross border tax issue. Tax treaties allow taxpayers to obtain tax refund in the foreign country if the the IRS wants to allocated more taxable income to the USA. Likewise, the IRS will provide a refund if another country is successful in its assessment of additional tax.
We have assembled the IRS international audit guide below. You will learn how to protect yourself and how to better plan your cross border pricing. By the way, you can obtain an IRS private letter ruling on your related party pricing.
- Development of IRC section 482 Cases
- The Final IRC section 482 Regulations
- Economic Assistance
- Approaching IRC section 482 Examinations
- Searching for Comparables
- Selecting the Method
- Computing the Adjustment
- Assistance from Counsel
- On-Site Visitations
- Development of IRC section 482 Cases — General Audit Procedures and Techniques
- Presentation of Findings
- Transfer Pricing Functional Analysis Questionnaire