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GGD-94-206R 1 (1994-09-15)

handle is hein.gao/gaobackrh0001 and id is 1 raw text is: Is 212.0 GAO United States General Accounting Office Washington, D.C. 20548 General Government Division B-258362 September 15, 1994 The Honorable Byron L. Dorgan United States Senate Z rE e t .is Dear Senator Dorgan: This letter responds to your request for updated information on the Internal Revenue Service's (IRS) administration of section 482 of the Internal Revenue Code, which deals with transfer pricing issues. The enclosed statistical information summarizes IRS' recent experience with section 482 in examinations, appeals, and litigation, following up our 1993 testimony International Taxation: Updated Information on Transfer Pricing (GAO/T-GGD-93-16, Mar. 25, 1993). The information was developed from IRS international examination and appeals data covering the late 1980s through 1993, and from 1993 and 1994 U.S. Tax Court rulings. We did not audit any of IRS' management information systems from which we obtained section 482 data. An IRS internal audit report pointed out problems with some international management information systems, which IRS is improving. The management information we used, however, was the best available for full analysis at the time we did our work, which we did in accordance with generally accepted government auditing standards. As agreed with your office, unless you publicly announce its contents earlier, we plan no further distribution of this correspondence until 30 days from the date of this letter. At that time, we will send copies to IRS and GAO/GGD-94-206R Information on Transfer Pricing V -

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