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Biases, Heuristics, Blind Spots, and Pitfalls in I.R.S. Transfer Pricing Exams

  • New York United States (map)

When a taxpayer receives an information document request (“I.D.R.”) from the I.R.S. for transfer pricing documentation, it should know what to expect: a lengthy, contentious process of documenting and defending its tax position. Pausing to think objectively about the cognitive biases, strengths, and weaknesses underlying a transfer pricing position is an essential step to take before delving into the technical aspects of the examination itself.

This seminar will cover common biases and heuristics that cause controversy during transfer pricing exams. The goal is to enable participants to recognize sources of disagreement between client positions and I.R.S. assertions so that rationale steps can be taken to resolve issues in a way that is neither exorbitant for the client nor embarrassing for the examiner. Common pitfalls and blind spots will be presented within the context of the recently published I.R.S. Transfer Pricing Examination Process guidance and compared to foreign law and tax authority practice.

Who Should Attend

This is a seminar for foreign attorneys and legal advisers that may find themselves acting for a client undergoing an I.R.S. transfer pricing examination or advising a foreign parent company on the foreign impact of an I.R.S. examination.


Michael Peggs, Transfer Pricing Economist
Stanley C. Ruchelman, Chairman


12:00 P.M.  Welcome Lunch
12:30 P.M.  Presentation


CLE 1.0 Areas of Professional Practice (non-transitional)*
CPE 1.0 Taxation

Date & Time

Wednesday, November 7
12:00 P.M. – 2:00 P.M.
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Ruchelman P.L.L.C.
150 East 58th St., 22nd Fl.
New York, New York 10155


*Application for New York accreditation of this course is currently pending.

For questions regarding this and other Ruchelman events, contact lapper@ruchelaw.com.