Fenwick & West

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Fenwick & West Market Insights (1)

The changing landscape of transfer pricing in the United States: Section 482 audits
The landscape of transfer pricing in the United States is subject to continuing change. The IRS is close to promulgating permanent aggregation regulations to replace temporary regulations due to expire. These anticipated new regulations may make it easier for the IRS to disregard complex transfer pricing structures and, further, reflect the US taxi...