IRS Takes Next Steps in International Realignment
Practical International Tax Strategies
In this article, Rocco Femia, Kevin Kenworthy, George Clarke, Kathryn Morrison Sneade, Sat Nam Khalsa and David Blair discuss the IRS's announcement of further organizational changes intended to improve the agency’s administration of the U.S. international tax and transfer pricing rules. The latest changes are intended to expedite processing of Advance Pricing Agreements and resolution of bilateral transfer pricing and other competent authority disputes. The changes also should facilitate easier IRS coordination with U.S. treaty partners. Although the changes and incidental increase in resources appear promising, as with any restructuring, only time will tell whether the IRS will achieve its objectives.