Transfer Pricing Compensating Adjustments: Another IRS Loss

Overview


Cym Lowell wrote this bylined article on the compensating adjustment issues to be addressed following the IRS loss in BMC Software, Inc. v. Commissioner transfer pricing case. “The relationship of closing agreement in transfer pricing cases and compensating adjustments is inevitably complex, especially in situations where there are other debt-related issues in the years in question,” Mr. Lowell wrote.