Kyle Koemm, together with our colleague Antonio Curvello from
Daniel IP in Brazil, recently had their article on transfer pricing
published on IPWatchdog.
The article is available here , and is also available below:
During a 2019 Tax Executives Institute conference in Washington,
D.C., the Commissioner of the U.S. Internal Revenue Service (IRS),
Charles Rettig, proclaimed, "[I am] not a commissioner who
believes that the IRS loses because a judge rules against us in a
transfer pricing case, . . . [I am] a commissioner who thinks the
IRS loses if it doesn't keep bringing [transfer pricing]
cases." (see Lydia O'Neal, Rettig Doubles Down on Transfer Pricing
Cases, Bloomberg Tax: Daily Tax Report (Apr. 1,
2019). This declaration speaks volumes to Rettig's
intention of closing down in transfer pricing cases. Specifically,
the IRS under Rettig, has targeted improper transfer pricing of
intellectual property (IP) royalties remitted from foreign
subsidiaries to U.S.-based
