When Sam Maruca, the IRS’s first-ever transfer pricing director, spoke to TPWeek in October 2011, he said his aims for his time in office were to improve the organisation’s transfer pricing process. While no one could be accused of disagreeing with his goals, to improve enforcement, resources, skills and to focus on intangibles, transfer pricing practitioners think the new director could be banging his head against a brick wall because of the structure of the IRS. Two lawyers, with IRS experience, tell Sophie Ashley how Maruca’s goals translate into the marketplace.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The allegations against Deloitte Cyprus raise uncomfortable questions about how far the big four can distance themselves from misconduct at member firms
Former IRS commissioner Danny Werfel joins ITR for a must-listen conversation spanning his time leading the agency, his AI risk framework, and the future of the OECD
Ex-EY and Hourani & Partners leader Zain Satardien is using flexible staffing and AI-enabled systems to test a leaner model for specialist legal and tax advice
The big four firm is rightfully prioritising transparency and accountability as it seeks to rebuild from its scandal, but a glaring structural issue remains