Eight Taxpayers Withdrew Pending Advance Pricing Agreements from IRS Program, Latest Statistics Show

U.S. taxpayers withdrew a total of eight cases from the Internal Revenue Service’s Advance Pricing Agreement Program during the quarter ended March 31, according to…

IRS Official Predicts Scrutiny of Offshore Compliance, Transfer Pricing

Transfer pricing, withholding for nonresident aliens, and offshore compliance will be a major focus of scrutiny for the Internal Revenue Service in the global arena, new…

U.S. Advance Pricing Agreements Completed in 2009 Drop to 63; Longer Times for Bilaterals, Report Shows

The Internal Revenue Service’s 11th annual statutory report on advance pricing agreements, released March 29 in Announcement 2010-21, showed fewer APAs completed in 2009 than in 2008 and also showed the APA Program is taking longer to complete cases, particularly bilateral agreements.

Administration’s International Tax Proposals Stand-Alone Provisions, Not Package, Treasury International Tax Counsel Says

The international tax proposals in the Obama administration’s fiscal year 2011 budget should be viewed as individual provisions that can be included in legislation for…

IRS Stressing Focus on Global Examinations, Seeking More Data on Taxpayers, KPMG Says

The Internal Revenue Service is intensifying its approach on audits of international issues, seeking increased information from taxpayers, and amping up not just…

Ninth Circuit Reissues ‘Xilinx’ Opinion, Affirms Tax Court Ruling on Stock Options

The U.S. Court of Appeals for the Ninth Circuit March 22 reissued its opinion in the Xilinx case on stock options to find for the taxpayer, reversing the stance taken in…

IRS Focused on Global Issues, Greater Cooperation, Transparency, Former Deputy Commissioner Says

Taxpayers can expect a sharp focus on global issues at the Internal Revenue Service going forward, marked by closer relationships with other taxing authorities, an…

ANALYSIS: Readdressing Transfer Pricing in a Down Economy

In the third of a series of articles by authors from Ernst & Young LLP addressing tax issues arising in a down economy, Bob Ackerman, Dan Karen, Peyton H. Robinson…

IRS Completed 63 Advance Pricing Agreements, Received 127 Requests in 2009

The Internal Revenue Service completed 63 advance pricing agreements and received 127 APA applications during the 2009 calendar year, APA Program…

IRS Considering Veritas Loss in Cost Sharing Settlement Guidelines

Internal Revenue Service Deputy Chief of Appeals Kurt Meier Feb. 26 said his division is taking into account IRS’s recent loss in Veritas Software Corp. v. Commissioner as it considers…

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