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Friday, June 3, 2011
As reported in today's Daily Tax Report, IRS Deputy Commissioner (International) Michael Danilack on February 25 discussed the implications of the recent reorganization that created the Large Business & International Division in the IRS. Speaking at the Annual Conference of the U.S.A. Branch of the International Fiscal Association, Danilack said that the reorganization will allow the IRS to bring more, and better informed, resources to bear in the international area.
Danilack also discussed the progress of the transfer pricing practice pilot, a new audit initiative that he first announced in April 2010. At that time, he had said that the cases chosen for audit would be of "high strategic importance." At the recent IFA meeting, he said that the pilot is currently using the IRS's best resources to audit a small number of transfer pricing cases, although he indicated that the IRS did not plan to publicize the results of these audits. On a related topic, he said that the IRS is now engaged in one joint audit with another country, will soon start a second joint audit, and is in serious talks about two others.
Harold W. Pskowski, Managing Editor for U.S. International
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