Overview
International Tax Review quoted Steve Dixon in a recent article, “Taxpayers Warned Against Overreaction to IRS TP Letters.” The article addresses compliance alerts that the IRS sent in January to subsidiaries of more than 180 foreign corporations as part of its Large Foreign-Owned Corporations Transfer Pricing Initiative. Steve explained that “[i]t’s important that taxpayers do not overreact to these ‘soft’ or ‘nudge’ letters from the IRS.” He also noted that these letters don’t reflect final determination that a taxpayer has underpaid its US taxes. He advised that “taxpayers should instead consult with US advisers about the best course of action.”
You can read the full article at International Tax Review (subscription required).