Ryan Finley evaluates whether the IRS’s recent success in transfer pricing method disputes is likely to hold up.

Transfer pricing refers to the pricing of goods, services and intellectual property transferred between related entities within a multinational corporation. Companies use transfer pricing to allocate ...

Rule 81 prescribes dataset construction, weighted averages, and a 35th–65th percentile arm’s length range when multiple comparable prices arise, with the median applied if the transaction falls ...