Want To Know How A Corporate Tax Executive Won Every IRS Transfer Pricing Case? A retired Tax Partner of an international law firm, a former CPA with a national accounting firm, and a Head of Tax of a multinational corporation, who never lost an IRS transfer pricing controversy, shared with me recently what he believes the biggest exposure is for multinationals today. Multinational companies transfer pricing methodologies will now be exposed for shifting profits and claiming certain functions are performed in countries they are not. Maybe they were in that country a few years ago but not now. He said many corporate tax executives are likely unaware of their transfer pricing exposure. As you know, transfer pricing requires highly technical skills, knowledge and expertise.