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U.S. IRS LB&I Division Memos Published with New Instructions for Transfer Pricing Examinations

18 January 2018

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Approved Changes

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United States

A number of instruction memos from the Commissioner of the IRS Large Business and International Division (LB&I) have been published in relation to transfer pricing examinations. These include: Interim Instructions on Issuance of Mandatory Transfer Pricing Information Document Request (IDR) in LB&I Examinations, which provides that mandatory transfer pricing IDR is no longer required for all cases; and Instructions for LB&I on Transfer Pricing Selection and Scope of Analysis - Best Method Selection, which provides that examiners may not change the applied transfer pricing method selected by the taxpayer unless approval has been obtained from the Transfer Pricing Review Panel,...