P. Stackhouse, Kent
Exchange of information in the new era of multirateral transfer pricing enforcement / by Kent P. Stackhouse, Donna McComber, and Giulia Di Stefano .-- , 2024
Kent P. Stackhouse and Donna McComber are principals and Giulia Di Stefano is a senior in the international tax and transaction services practice at EY’s National Tax Department in Washington. In this article, the authors provide an overview of exchange of information programs commonly used by the IRS that are relevant to an audit in the United States and abroad, offer examples of taxpayer concerns with exchange of information, suggest approaches to manage potential implications, and identify future concerns. The views expressed below are those of the authors and do not necessarily reflect the views of Ernst & Young LLP or any other member firm of the global EY organization. The information in this article is provided solely for the purpose of enhancing knowledge. It does not provide accounting, tax, or other professional advice.
PRECIOS DE TRANSFERENCIA
INTERCAMBIO DE INFORMACION TRIBUTARIA
ESTADOS UNIDOS
McComber, Donna
Di Stefano, Giulia
Tax Notes International 1048-3306 v. 114, n. 5, April 29 2024, p. 661-668
Exchange of information in the new era of multirateral transfer pricing enforcement / by Kent P. Stackhouse, Donna McComber, and Giulia Di Stefano .-- , 2024
Kent P. Stackhouse and Donna McComber are principals and Giulia Di Stefano is a senior in the international tax and transaction services practice at EY’s National Tax Department in Washington. In this article, the authors provide an overview of exchange of information programs commonly used by the IRS that are relevant to an audit in the United States and abroad, offer examples of taxpayer concerns with exchange of information, suggest approaches to manage potential implications, and identify future concerns. The views expressed below are those of the authors and do not necessarily reflect the views of Ernst & Young LLP or any other member firm of the global EY organization. The information in this article is provided solely for the purpose of enhancing knowledge. It does not provide accounting, tax, or other professional advice.
PRECIOS DE TRANSFERENCIA
INTERCAMBIO DE INFORMACION TRIBUTARIA
ESTADOS UNIDOS
McComber, Donna
Di Stefano, Giulia
Tax Notes International 1048-3306 v. 114, n. 5, April 29 2024, p. 661-668