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Transfer Pricing Examination Process: Resolution Phase (Part VII) | TaxConnections
III. Resolution Phase The goal of the resolution phase is to reach agreement, if possible, on the tax treatment of each issue examined and, if necessary, issue a Revenue Agent Report (RAR) to the taxpayer. Starting with the development of the issue and continuing through resolution, early and frequent discussions with the taxpayer are crucial for a complete understanding of the respective merits of an issue. A. Issue Presentation and Resolution The issue team should meet with the taxpayer to discuss results of all issues prior to finalizing the NOPA and the Economist Report. Focus taxpayer discussions on the following