Patricia Lewis Moderates Transfer Pricing Panel Discussion


Bloomberg BNA provides a recap of a transfer pricing webcast where Patricia Gimbel Lewis served as panel moderator.  Ms. Lewis asked questions regarding IRS resources in relation to the APA process, bilateral discussions regarding key safe harbor issues, and the IRS' current thinking regarding the OECD model safe harbor MOUs. For the complete article, please visit Bloomberg BNA's website (subscription required).

Excerpt taken from the article.

Responding to a question from panel moderator Patricia Lewis of Caplin & Drysdale regarding IRS resources, Hughes said the kind of streamlined APA process that the Service is envisaging "might not actually be too far outside of things we are normally doing already."

Lewis asked if IRS would consider working out informal bilateral understandings with its treaty partners as to what the key safe harbor issues are regarding a particular bilateral relationship.

Hughes said IRS is contemplating such an approach. Once the agency has a workable framework in place and has a good sense of the kind of taxpayers that would be seeking to use a safe harbor, he said, perhaps the regime could be rolled out—"in whatever form it might be"—in various stages.

Lewis asked Hughes whether the IRS is planning to tweak the OECD Model Treaty's safe harbor MOU and then use it as template for multiple treaty partners.

Hughes said the Service's current thinking is to start with the OECD model template because there is no need to reinvent the wheel.


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