In the past, the IRS did not uniformly audit transfer pricing. In fact, a study in 2004 and 2005 revealed that despite a directive from the Commissioner that all international audits had to ask for transfer pricing documents; only about 50% of the auditors asked for the material. The IRS amended the Agent’s Handbook to mandate that a request on International IDR No. 1 be issued on the first day of the audit. In general you have 30 days to respond with rare exceptions. Territory managers are now reviewing the IDR logs to assure themselves that the transfer pricing documents have been requested. In addition, the world has changed since 1994 when the U.S. and perhaps one other country requested some sort of documentation. Now over 45 countries have specific rules and requirements. If you have not prepared documentation, it is imperative that you review your exposure. This is regardless of whether your outside audit firm has raised the issue under ASC 740 or not. The days of not preparing transfer pricing documentation are coming to a close. Seek a professional to assist you in reviewing your circumstances. My preference is that you engage an attorney experienced in transfer pricing to ascertain the exposure in order to have some privilege over the process.