Transfer Pricing Positions of Consolidated Groups: After Guidant

Volume 3 No 4   |   Read Article

By Michael Peggs and Kenneth Lobo

Michael Peggs and Kenneth Lobo comment on the I.R.S. victory in the Guidant case where the I.R.S. applied the “one size fits all” approach to group-wide transactions. Their conclusion is that today’s I.R.S. victory may be tomorrow’s lost revenue where a taxpayer seeks competent authority relief for transfer pricing adjustments initiated abroad.  See more →