EYUS IRS examiners must consult IRS counsel before applying the economic substance doctrine in transfer pricing audits
|Tax Alerts, Transfer Pricing, Legislatio ...|United States
On 18 January 2023, Robin Greenhouse, the Large Business and International (LB&I) Division Counsel, stated at a meeting of the American Bar Association Section of Taxation that examiners still must consult with IRS counsel before asserting related penalties related to the economic substance doctrine (ESD).1 The statement follows an Internal Revenue Service (IRS) decision to no longer requ…
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