Law360 | IRS Not Likely To Back Away from Privilege Fights

The judicial branch was busy over the summer churning out transfer pricing cases. This article discusses two bellwether transfer pricing decisions defining the Internal Revenue Service’s ability to cancel advance pricing agreements and how the arm’s-length standard applies to high-value intercompany licensing transactions.

Alston & Bird has broadened its transfer pricing and international tax capabilities with the addition of counsel E. Miller Williams, Jr. in the firm’s Atlanta office. Joining from Ernst & Young, where he was a principal, Williams advises multinational companies on complex transfer pricing matters, with an emphasis on international transfer pricing controversy, audits, advance pricing agreements, competent authority, and intercompany planning and structuring.

Ryan Kelly is quoted on the Internal Revenue Service’s resumption of examinations of stock-based compensation in cost-sharing arrangements.

Ryan Kelly comments on how employee resource constraints are causing a decline in Internal Revenue Service audit rates.

Ryan Kelly comments on the Internal Revenue Service’s transfer pricing dispute with the Coca-Cola Co.