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Law360 Quotes Patricia Lewis: IRS 'Reference Set' Library Could Speed Up Transfer Pricing Cases
Caplin & Drysdale

Law360 Quotes Patricia Lewis: IRS 'Reference Set' Library Could Speed Up Transfer Pricing Cases

Date: 6/18/2018

The IRS is trying to create a “reference set library” of comparable company data used as benchmarks in transfer pricing cases — a move tax practitioners said could save time in audits or advance pricing agreements.

. . .

Patricia Lewis of Caplin & Drysdale, Chtd. said the reference sets may be “as close as [the IRS] can get at the moment” to a safe harbor.

“I suppose you could publish a reference set as informal guidance, just not as something taxpayers could take to the bank,” she told Law360 Friday.

To view the full article, please visit Law360's website (subscription required).

Excerpt taken from the article “‘Reference Sets’ Could Speed Up Transfer Pricing Cases" by Molly Moses for Law360.

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