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ARTICLE · 16 DECEMBER 2021

Looking Forward: Predictions For 2022

Mayer Brown
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In ancient Rome, a college of "augurs" would predict the future by observing the flight patterns of birds, examining the entrails of animal sacrifices, or interpreting natural phenomena. While perhaps less colorful, ...

United StatesTax
John T. Hildy
John T. Hildy
Elena B. Khripounova
Elena B. Khripounova
Jason Osborn
Jason Osborn
Astrid Pieron
Astrid Pieron
Anthony D. Pastore
Anthony D. Pastore
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In ancient Rome, a college of "augurs" would predict the future by observing the flight patterns of birds, examining the entrails of animal sacrifices, or interpreting natural phenomena. While perhaps less colorful, our method of divination will hopefully be a little more precise. To develop this blog post, we have consulted our own augurs and have summarized all our predictions for transfer pricing developments in the coming year.

  • More Enforcement Overall. Three factors may lead to significantly increased transfer pricing enforcement in 2022. One, the Biden administration's Build Back Better proposal includes a sizeable increase in the IRS's enforcement budget, and, to increase revenue, the proposal leans heavily on the IRS's ability to collect more tax from large multinationals. Two, the IRS has recently managed to reverse the perception that it has not fared well in big-ticket transfer pricing litigation. Several notable wins in the US Tax Court and in other

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This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.

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