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 future chief tax officer will be judged not only on compliance, but on their ability to harness data, technology and AI to support strategic decision-making
Ryosuke Takemura, OECD policy adviser, countered that the organisation’s role is ‘not to solve these issues one by one’ but to prevent tax disputes in general
Howden’s Rian Bahia explains how tax insurance can address known risks, unlock transactions and offer an alternative route through disputes and uncertainty
Haynes Boone’s new London partner, Alexandra Ueno-Park, argues that one-size-fits-all policies, billable-hour targets and outdated networking expectations can hold talent back