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

Daily Tax Report: State provides authoritative coverage of state and local tax developments across the 50 U.S. states and the District of Columbia, tracking legislative and regulatory updates,...

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.