According to recent reports, U.S. Treasury Attorney Advisor Brian Jenn has stated that the U.S. won't need to issue any new regulations to implement changes to the OECD transfer pricing guidelines developed as part of Actions 8, 9, and 10 of the Base Erosion and Profit Shifting (BEPS) Project. According to Jenn, the U.S. already has detailed guidance under Internal Revenue Code section 482 that goes beyond the OECD guidelines being developed and doesn't feel that any final deliverables from the OECD work on those BEPS Actions need to be added in U.S. regulations. As the work on the Actions...