States have recently started to use third party contract auditors to conduct transfer pricing audits of taxpayers. Such audits have resulted in large assessments made pursuant to the states’ “discretionary authority.” This article, recently published by Kendall Houghton and Maryann Luongo in the IPT’s August 2011 Tax Report (see p. 15), discusses the use of third party contract auditors in the transfer pricing arena as well as some of the issues that arise during such audits.
About Jasper L. (Jack) Cummings, Jr.
Jack Cummings is counsel in the Federal Tax Group of Alston & Bird in Raleigh and Washington, D.C. He served as IRS associate chief counsel (corporate) and chair of the Corporate Tax Committee of the ABA Section of Taxation.
About Edward Tanenbaum
Edward Tanenbaum is co-chair of the firm’s Federal & International Tax Group and a member of the firm’s Global Resources & Strategies Committee. Mr. Tanenbaum’s practice consists primarily of planning and structuring tax efficient solutions for cross-border business transactions and investments by foreign multinational corporations and high-net-worth individuals.