IRS Launches New "Transfer Pricing Practice" - Pilot Program Will Select Audit Cases for Scrutiny

This article was originally published in Tax Alert, May 5, 2010

The IRS recently announced that it is taking new steps to improve its effectiveness in transfer pricing audits. In a series of speeches, top IRS officials announced the creation of a "Transfer Pricing Practice" within the Large and Mid‐Size Business (LMSB) operating division to "strategically and systematically administer transfer pricing issues." This Practice (new terminology for the IRS) will assemble a group of experts from various parts of the IRS to better coordinate the handling of key transfer pricing cases and identify emerging issues. More efficient transfer pricing examinations as well as more consistent treatment of issues across the country are among the stated goals. Marshalling IRS expertise "to match up with corporate taxpayers" was specifically mentioned. At present, it is not entirely clear how the new Practice will interact with the existing Issue Management Teams, which