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 approaches adopted by...

The United States and Australia, despite labeling gig workers in similar ways, differ in their approach to gig workers’ rights.