Rocco Femia was quoted regarding the Organization for Economic Cooperation and Development's (OECD) action plan to address base erosion and profit shifting (BEPS), specifically as it relates to transfers of hard-to-value intangibles, in the context of an international tax conference sponsored by George Washington University and the IRS. Femia questioned whether other countries have shown interest in the U.S. commensurate-with-income rules as a means of addressing such transfers, and whether the OECD was interested in input from practitioners on that question. "Is that the kind of thing that is happening in the brainstorming and the kind of thing you want more input on?" he asked. Representatives of the IRS responded that there is much interest in the U.S. rules, and in the absence of comparables or reliable projections, the commensurate-with-income rule can be the most reliable information source to determine transfer prices.