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US | Increased IRS funding from Inflation Reduction Act will likely affect transfer pricing cases

19 August 2022

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Tax Alerts, National/Federal Taxation, Transfer Pricing, Information Reporting, Legislation & Policy

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United States

Increased funding for IRS enforcement, provided under the newly enacted the Inflation Reduction Act, will likely increase IRS scrutiny of transfer pricing cases. Taxpayers should proactively enhance their transfer pricing documentation and consider tax dispute resolution tools.The United States (US) Inflation Reduction Act (IRA), enacted on 16 August 2022, allocates nearly US$80 billion1 in new funding for the Internal Revenue Service (IRS). Of that $80 billion, more than $45 billion is for enforcement (including the determination and collection of "owed taxes"), more than $25 billion is for operations, nearly $5 billion is for systems modernization, and over $3 billion is for customer service,...