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US IRS launches new initiative to strengthen transfer pricing enforcement

16 November 2023

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Tax Alerts, Transfer Pricing, National/Federal Taxation, Transfer Pricing

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United States

The IRS announced (IR-2023-194) on October 20, 2023, that it plans to send compliance alerts to approximately 150 US-based subsidiaries of foreign-owned corporations that distribute goods in the United States. The alerts stem from the companies' alleged use of certain transfer pricing strategies, which the IRS deems improper.The IRS also said in the news release that it plans to expand the Large Corporate Compliance program in 2024 to audit 60 additional large corporate taxpayers, which will be selected with the help of artificial intelligence.BackgroundThe Inflation Reduction Act, enacted on August 16, 2022, allocated nearly $80 billion in new funding for...