All-In: The IRS’s High-Stakes Bet on Periodic Adjustments

Clark Armitage and Elizabeth Stevens co-authored the article "All-In: The IRS’s High-Stakes Bet on Periodic Adjustments" published in Tax Notes on July 24, 2025. 

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Elizabeth J. Stevens and J. Clark Armitage are members in the Washington office of Caplin & Drysdale Chtd. Armitage is a former deputy director of the IRS advance pricing agreement program.

In this article, Stevens and Armitage critique Treasury regulations and IRS guidance governing periodic adjustments to the pricing of transfers of intangible property, and they analyze ways for controlled taxpayers to adapt to and mitigate the risk of such adjustments.

For the full article, please visit Tax Notes' website (subscription required) or Related Materials below.