IRS representatives have recently addressed the IRS's current approach to asserting penalties in transfer pricing cases, saying that both the documentation and method of transfer pricing must pass muster.On September 18, 2024, Michelle Ng, IRS Office of Associate Chief Counsel (International) attorney, said that taxpayers should consult IRS FAQs on transfer pricing documentation so they can understand what the IRS is requesting.1 In addition to documentation backing up a taxpayer's position, however, the chosen method of transfer pricing must also be reasonable, she said.2This comes after Brad Anwyll, IRS Transfer Pricing Practice director of field operations, said at a TEI...