Rocco Femia discusses the outlook for U.S. transfer pricing developments in 2012, including IRS transfer pricing enforcement and potential legislation. With regard to enforcement, Femia notes the importance of case selection—something IRS Transfer Pricing Director Samuel Maruca has emphasized repeatedly—to IRS as an institution. "It doesn't do the IRS any good to spend time on cases that don't present significant issues for it," Femia says. "Whatever they can do to get better at case selection is beneficial for the IRS and for taxpayers who are taking reasonable positions."