Rocco Femia led a panel at the ABA Tax Section meeting on the cost sharing transfer pricing landscape in light of the Veritas and Xilinx decisions. Discussing an IRS transfer pricing pilot program announced in April, Femia said the earlier involvement of APA transfer pricing specialists is unlikely to generate more reasonable positions on cost sharing buy-in payments. "You see these very, very large adjustments and, at least from my perspective, that's not really rogue agents in the field," Femia said. "These are positions that are taken by very capable people throughout the organization and in the National Office."