Law360 Quotes Mark Allison on 5 Things Keeping Tax Attorneys Up At Night


Mark D. Allison comments on what keeps tax attorneys up at night, including international efforts to crack down on tax evaders, the looming possibility of a revamp of the U.S. tax code, and an underfunded Internal Revenue Service.  For more on the story, please visit Law360's website (subscription required).

Excerpt taken from the article.

Transfer Pricing
For attorneys who represent large multinational companies in tax litigation, transfer pricing is at the top of the list of concerns keeping them up at night, according to Mark D. Allison of Caplin & Drysdale Chtd.
Tax administrations in the U.S. and around the world are increasingly turning their attention to the way companies price goods and services sold in intracorporation deals. The amounts involved in transfer pricing are so large that billions of dollars can hang in the balance of a single case or audit.
While authorities have the right to pursue the cases, it's being done inefficiently on a country-by-country basis, Allison said. With so much at stake, companies are having to devote enormous resources to insulate themselves from and defend against transfer pricing disputes in several jurisdictions at once, leading to late nights and indigestion on the part of tax attorneys and their clients, he said.
To make matters worse, the successful resolution of one transfer pricing case can lead to the instigation of another as countries fight for the tax revenue they see as rightfully theirs, Allison said.

"When you've got global taxpayers who are getting hit from multiple directions from multiple taxing authorities, it's putting a lot of strain on the system," Allison said. "It's an issue that just never seems to go away."


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