Transfer pricing, or the practice of pricing transactions between related parties, has increasingly become an enforcement priority for many tax authorities. In this article for the Journal of Tax Practice & Procedure, George Hani, Brian Gleicher, and Jaclyn Roeing examine how this growing scrutiny affects U.S. taxpayers engaged in cross-border transactions. They outline the legal and regulatory framework, the Internal Revenue Service's (IRS) audit process, and the global influence of Organisation for Economic Co-operation and Development (OECD) initiatives like Base Erosion and Profit Shifting (BEPS) 2.0. The authors also explore the role of U.S. tax treaties, competent authorities, and the Mutual Agreement Procedure (MAP) as critical tools for resolving disputes and avoiding double taxation. They conclude that taxpayers must stay vigilant, strategically manage audits and documentation, and monitor litigation developments to effectively navigate the evolving transfer pricing landscape.