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

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.

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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.

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