A number of instruction memos from the Commissioner of the IRS Large Business and International Division (LB&I) have been published in relation to transfer pricing examinations. These include:
- Interim Instructions on Issuance of Mandatory Transfer Pricing Information Document Request (IDR) in LB&I Examinations, which provides that mandatory transfer pricing IDR is no longer required for all cases; and
- Instructions for LB&I on Transfer Pricing Selection and Scope of Analysis - B…