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We are a leading independent tax and business advisory services firm specializing in international tax consulting, transfer pricing, valuation and tax process innovation.

We operate throughout North America and cover over fifty countries through strategic alliances with firms across the globe.

Accomplished Professionals

Our team of highly-experienced professionals consists of former Big 4 tax specialists, economists, attorneys, CPAs and MBAs, each with decades of experience delivering tax, transfer pricing, valuation and tax innovation services.

Our senior professionals are directly engaged in the work we deliver to our clients - unlike many large firms that employ a “leverage model” relying on less experienced personnel to do most of the work.

Delivering Value to Our Clients

Our clients include private and public companies ranging from emerging businesses to Fortune 50 companies. They include U.S. and non-U.S. based multinationals operating in a wide array of industries, including industrial manufacturing and distribution, aerospace, food processing and distribution, agriculture, medical products manufacturing and distribution and financial services.

Our clients seek responsive, collaborative professionals who deliver services efficiently and cost effectively. We willingly share our knowledge and insights to help our clients understand the technical issues and enhance their ability to make informed, strategic decisions with confidence.

What to Expect When You’re Expecting… A Transfer Pricing Examination?

Posted on May 1st, 2019

Transfer pricing examinations can be unpleasant experiences for taxpayers. Chances are, an international business in the U.S. – whether it is headquartered in the U.S., or a subsidiary of a foreign parent – is going to have its transfer pricing examined by the IRS or another tax authority.

Transfer pricing has been cited by IRS officials for years as one of their most important enforcement priorities. But as a direct result of BEPS (the OECD’s Base Erosion Profit Shifting project), tax authorities around the world are actively engaged in the process of revising and tightening their expectations and requirements with respect to transfer pricing. The prospect of thorough and detailed examinations of taxpayers’ transfer pricing positions is growing every day.

Fortunately for multinational companies operating in the U.S., an important document exists that can help taxpayers be better prepared for the eventual IRS transfer pricing exam: The Transfer Pricing Examination Process, Publication 5300 (TPEP). Originally released in June 2018, the TPEP is a 37-page guide prepared by the IRS for its issue teams to help them be better prepared to examine the transfer pricing positions of taxpayers, and it lays out in considerable detail the process and expectations surrounding such an examination. The TPEP replaces the Transfer Pricing Audit Roadmap, which was issued in 2014. WTP Advisors’ Guy Sanschagrin and Doug Schwerdt authored a comprehensive review of the TPEP, “Review of and Insights on the IRS Transfer Pricing Examination”, which was published by Tax Notes International on March 18, 2019. This article contains key insights to help taxpayers be better prepared and it can be accessed by clicking here.

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