SALT TP

The 2022 SALT Transfer Pricing Quiz (the “Quiz”) is anything but your run-of-the-mill test of knowledge.

We created the six multiple-choice question Quiz based on our two-part Tax Notes State article, “SALT Transfer Pricing — What You Need to Know” (“the article”), which was published in January 2022. The Quiz is designed to reinforce foundational “SALT 101” and “TP 101” level content and recent developments in these interrelated tax fields. You’ll score well on the Quiz if you have basic SALT and transfer pricing know-how, even without reading the article.

Launch Quiz!

However, if you’re unsure of your Quiz answers, all correct answers (and instructions on how to determine the answer to the sixth and final question) can be found in SALT Transfer Pricing — What You Need to Know: Part 1 and SALT Transfer Pricing — What You Need to Know: Part 2. We can share a limited number of copies of the article with interested readers. You can request the article within the Quiz or by contacting Guy Sanschagrin or Doug Schwerdt of WTP Advisors.

Trying to gauge your interest in diving deeper into SALT transfer pricing? Check out our recent flyover of Part 1 of the article: Six “SALTy” Transfer Pricing Facts.

We hope you enjoy self-assessing your SALT transfer pricing know-how, competing with tax peers to become the “2022 SALT Transfer Pricing Quiz Champion,” and taking home a prize from a lineup of emblematic Peugeot SALT mills/grinders – your choice from an array of colors that are reminiscent of the American flag.

The deadline for online Quiz submission is Saturday, April 30, 2022.

WTP Advisors is administering the Quiz and all of your Quiz responses (score, name, etc.) will be kept in strict confidence (all Quiz submission data will also be deleted on May 31, 2022).

 


If you have any questions or would like more information on this blog post or the Quiz, please contact the authors:

Guy Sanschagrin, Principal in Charge of Transfer Pricing and Valuation Services, WTP Advisors    guy.sanschagrin@wtpadvisors.com

Doug Schwerdt, Transfer Pricing Specialist & Intra-Group Financial Transactions Leader, WTP Advisors    doug.schwerdt@wtpadvisors.com

 

#TransferPricing #SALT #MTC #SITAS #WTPAdvisors #TransPortal #SALTpartners #TGS #ThinkGlobalSustainability   

Six Time-Tested Transfer Pricing Examination Process Takeaways

While we have periodically written about the Transfer Pricing Examination Process, Publication 5300 (TPEP) and its predecessor, the Transfer Pricing Audit Roadmap, for this blog post we revisited the TPEP to determine how well this IRS guidance and our initial insights on it have withstood the test of time relative to our field-based transfer pricing (“TP”) experience since the TPEP’s initial 29 June 2018 release. This blog post is a companion to our article “Impactful FYE Transfer Pricing Examination Preparedness Measures” in the December 2020 TGS Global AMÉRICA Regional Magazine. Following are six TPEP takeaways that we have found to be even more important today than a few years ago.

1. Robust documentation is the first and best line of defense against an IRS TP adjustment and non-deductible penalties and interest.

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Transfer Pricing Exams & IRS Preparedness Measures

In this fourth article in our Looming Transfer Pricing Exams & IRS Preparedness Measures series, we briefly summarize the IRS’s Transfer Pricing Examination Process (TPEP) Resolution Phase, which is the final phase of the TPEP’s three phases, and we list extrajudicial taxpayer courses of action such as Appeals.

The goal of the Resolution Phase is to reach agreement on the tax treatment of each transfer pricing issue examined. Important parts of the Resolution Phase include the IRS’s presentation of the issue and its resolution, case closing, and when necessary, issuing a Revenue Agent Report with adjustments, penalties (if the taxpayer failed to timely provide documentation), and tax liability.

The TPEP instructs the issue team to provide the taxpayer an opportunity to agree or disagree with the findings for each transfer pricing issue developed during the examination. For a transfer pricing issue to be resolved, there must be an open discussion between the issue team and the taxpayer in three areas: 1) factual development, 2) the law(s) that applies to the facts, and 3) each party’s interpretation of the law(s). The issue team should meet with the taxpayer to discuss all issues and determine whether a “principled resolution” can be reached. If a field resolution is not reached, the issue team will finalize the Notice of Proposed Adjustment (“NOPA”) and Economist Report.

The TPEP discusses options that the taxpayer can pursue, including Appeals,[1] and when a tax treaty country is involved, U.S. Competent Authority (CA) requests, Accelerated CA Procedures to cover subsequent taxable years, and Simultaneous Appeals Procedures whereby Appeals works jointly with the Advance Pricing and Mutual Agreement (APMA) Program and the taxpayer prior to APMA’s consultations with the foreign CA(s). Taxpayers may request CA assistance after receiving a NOPA and are not required to wait until the conclusion of an examination to file a CA request. If APMA accepts a CA request, it will assume jurisdiction over the transfer pricing issues. Otherwise, the case remains under the jurisdiction of the issue team.

We invite you to read our article Six Time-Tested TPEP Takeaways where we share pertinent insights that are even more important today than a few years ago when the TPEP was still hot off the press.

Stay tuned for the next blog post in this series, where we discuss the IRS’s April 2020 transfer pricing guidance, Transfer Pricing Documentation Frequently Asked Questions (FAQs).

If you have any questions or would like more information on the issues discussed in this article, please contact the authors:

Guy Sanschagrin, Principal in Charge of Transfer Pricing and Valuation Services, WTP Advisors (Minneapolis, MN, USA) guy.sanschagrin@wtpadvisors.com

Doug Schwerdt, Transfer Pricing and Valuation Specialist, WTP Advisors (Houston, TX, USA) doug.schwerdt@wtpadvisors.com

 

Read Blog Post Part 1 in this Series

Read Blog Post Part 2 in this Series

Read Blog Post Part 3 in this Series

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[1] The TPEP reaffirms that the IRS requires 365 days to remain on the statute of limitations for taxpayers to request Appeals consideration.

Doug Schwerdt

In this third article in our Looming Transfer Pricing Exams & IRS Preparedness Measures series, we highlight and summarize the essential aspects of the IRS’s Transfer Pricing Examination Process (TPEP) Execution Phase.

The Execution Phase immediately follows the opening conference and consists of continued risk assessment, fact finding, information gathering, and issue development. Stages of issue development include determining the facts, applying the law to those facts, and understanding the various tax implications of the issue. The issue team is advised to make every effort to resolve factual differences with the taxpayer.

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