It Ain't Over ‘Til It's Over: State Tax Implications Of Implementing a Sustained Federal Transfer Pricing Adjustment

The Bloomberg BNA Tax Management Weekly State Tax Report filters through current state developments and analyzes those critical to multistate tax planning.

As the number of global transfer pricing controversies has escalated, there has been increased attention to the federal income tax consequences of a sustained transfer pricing adjustment. However, relatively little attention has been paid to the state tax consequences of a federal transfer pricing adjustment. In this article, authors Brian Cody, Sarah McGahan, Ian Novos, Shirley Sicilian and Troy Young identify some of the state substantive and procedural issues a taxpayer should consider after a §482 adjustment.