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Transfer Pricing

New “roadmap” provides detailed guidance on transfer pricing audits

New “roadmap” provides detailed guidance on transfer pricing audits

Click here for IRS’s “Transfer Pricing Audit Roadmap.” IRS’s Large Business and International division (LB&I) has issued a highly detailed “transfer pricing audit roadmap,” which includes audit techniques and tools to assist with transfer pricing examinations from early planning through resolution. The roadmap also provides a rough timeline for a transfer pricing exam and emphasizes […]

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More progress made on cross-border corporate tax pacts – U.S. IRS

More progress made on cross-border corporate tax pacts – U.S. IRS

More progress made on cross-border corporate tax pacts – U.S. IRS. (Reuters) – The U.S. Internal Revenue Service is making progress this year on minimizing quarrels with multinational corporations over “transfer pricing,” or taxing how companies value and move capital and assets across borders, a senior IRS official told Reuters. The agency has signed 115 […]

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Amazon fights $234 million tax liability in Tax Court

Amazon fights $234 million tax liability in Tax Court

Well, the IRS may have a fight on its hands as the giant Amazon is currently involved in a case pending before the U.S. Tax Court as Docket No.: 031197-12, and concerns proposed adjustments of over $234 million. The case, filed on December 28, 2012, in U.S. Tax Court in Washington, D.C., has implications for […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney