Budget Increases for Transfer Pricing Administration and Examination

The Obama Administration has made enforcement of transfer pricing legislation a priority. In fact, for the first time in IRS history, an internal Transfer Pricing Council will focus on specific transfer pricing issues.

The IRS also plans to create a transfer pricing “practice” where the most experienced international examiners, technical advisors and economists will work on high yield (high dollar value) cases. The first-ever director and chief economist dedicated to transfer pricing issues and regulation has also been appointed.

These moves reaffirm the increased commitment by the Treasury Department and the IRS to enforcement of international tax regulations.

In addition, the IRS has indicated that the Large and Midsize Business Division (LMSB) will be renamed the Large Business and International Division (LB&I). This change means 875 LMSB employees who previously specialized in international issues in previously designated industry divisions, will be realigned under the direction of the international unit’s new transfer pricing director.