Rocco Femia Quoted Regarding Restrained Use of CWI Standard in Tax Notes

"Practitioners Call for Restraint on Use of Ex Post Information"
Tax Notes
07.27.15Rocco Femia was quoted regarding the limited use to-date of the U.S. commensurate with income (CWI) standard. In a panel discussion at the National Association for Business Economics Transfer Pricing Symposium on July 22, 2015, Femia said that while the CWI provision of section 482 has been in place for nearly 30 years, it has not been invoked by the Internal Revenue Service (IRS) in litigation. The OECD's work on hard-to-value intangibles, however, may expand the use of ex post information under CWI-like principles by other countries.
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