A Comparative Approach to Documentation Methods and Avoiding Transfer Pricing Penalties: Is the United States Justified in Its Approach of Enforcing Penalties Under Section 6662?
By Atalya Santos | Volume 9 | Issue 1 This Note examines the Internal Revenue Service’s application of § 6662 accuracy-related penalties in transfer pricing disputes, with particular focus on how the agency evaluates the adequacy of contemporaneous transfer pricing documentation prepared by multinational corporations (MNCs). It argues that the United States’ penalty-centered enforcement model reflects an aggressive compliance strategy that diverges meaningfully from the appro
Atalya Santos
2 days ago
