Transfer Pricing

Our Firm has been extensively involved in transfer pricing planning, compliance and controversy resolution for our clients in a wide variety of industries. Despite voluminous "proposed," "temporary" and "final" government pronouncements, transfer pricing remains very subjective, and our experience in transfer pricing can be invaluable to our clients. While the price of goods exported from, or imported into, the United States is the most commonly addressed transaction, we also advise our clients with respect to intergroup licenses, cost sharing agreements, intergroup services and intergroup loans. New penalty provisions, recently issued final U.S. Treasury Department regulations and increased auditing efforts by the IRS and foreign governments have made transfer pricing a critical area for all U.S. taxpayers with international operations.

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McDermott Will & Emery

McDermott Will and Emery