IRS Advises Agents on Taxpayer Use of Section 482


Kevin Spencer said that a new IRS practice unit covering arms-length transactions with a foreign corporate parent gives revenue agents a useful checklist to determine whether a taxpayer has the proper documentation to support its position. “It summarizes, in a nice, digestible way for an agent, what is the relevant authority and what are the things the agent should look at to make sure the taxpayer has done it correctly, which is very helpful,” Mr. Spencer added.