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Fact-finding as shadowboxing: Be ready for the authorities

March 09, 2011

It seems the Internal Revenue Service (IRS) is preparing for the next round of transfer pricing controversy, which may prove to be a real barn-burner.

The IRS’s loss in Veritas was only round one. As noted by Steven Musher, IRS Associate Chief Counsel (ACC), Veritas was a “pre-eminently factual case” and the IRS’s non-acquiescence in the matter signals that it “is not stepping aside from attention to and pursuit of high-profile, high-risk transfer pricing issues”.

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