Uncertain Positions, FBAR Seen Having Transfer Pricing Implications

Recent IRS actions on uncertain tax positions and congressional action on reporting and disclosure requirements for foreign banks have implications for transfer pricing, KPMG LLP practitioners say. Taxpayers with transfer pricing issues should carefully consider both IRS's proposal to require disclosure of uncertain tax positions and a newly enacted tax code section extending the statute of limitations for failure to disclose cross-border transactions, Will Williams, a principal in KPMG's Washington National Tax group, economic & valuation services, says on a webcast.