Exchange of information in the new era of multirateral transfer pricing enforcement by Kent P. Stackhouse, Donna McComber, and Giulia Di Stefano
By: P. Stackhouse, Kent
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Contributor(s): McComber, Donna | Di Stefano, Giulia.
Material type: 
ArticlePublisher: 2024Subject(s): PRECIOS DE TRANSFERENCIA | INTERCAMBIO DE INFORMACION TRIBUTARIA | ESTADOS UNIDOS
In:
Tax Notes International v. 114, n. 5, April 29 2024, p. 661-668Summary: 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.
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| Artículos | IEF | IEF | OP 138-Bis/2024/114/5-2 (Browse shelf) | Available | OP 138-Bis/2024/114/5-2 |
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| OP 138-Bis/2024/114/4-5 Key transfer pricing developments unfolding in Brazil | OP 138-Bis/2024/114/5 Tax Notes International | OP 138-Bis/2024/114/5-1 Amount A impact analysis on U.S. corporate tax revenue | OP 138-Bis/2024/114/5-2 Exchange of information in the new era of multirateral transfer pricing enforcement | OP 138-Bis/2024/114/5-3 Let´s play fair | OP 138-Bis/2024/114/5-4 Fraudulent AI as an agent PE | OP 138-Bis/2024/114/5-5 Holding nothing back |
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.
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