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

This Note compares the Morrocan-Polisario Front conflict over Western Sahara to the Israeli-Palestinian conflict in hopes of taking the legal lessons from Israel and learning the best path forward for the Western Sahara conflict. Read the full Note here: