Mark Martin and Thomas Bettge of KPMG in the US discuss the US TP penalty regime and a recent shift towards more aggressive penalty enforcement by the IRS.
Mark Martin and Thomas Bettge of KPMG in the US discuss the latest consultation document on Amount B, which aims to simplify transfer pricing for baseline distribution activities and reduce disputes.
Mark Martin and Thomas Bettge of KPMG in the US discuss IRS alternative dispute resolution (ADR) and prevention programmes and how their underutilisation impedes effective tax administration.
Mark Martin and Thomas Bettge of KPMG in the US discuss the recently announced IRS procedures for reviewing advance pricing agreement (APA) requests and what these procedures mean for taxpayers.
