Mountain of Big Legal Cases Faces IRS: Transfer Pricing Report

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week we’re checking out the growing mountain of TP cases facing the IRS this year, even amid all the budget cuts and staffing departures at the agency over the last year. And we’re following up on the EU advisory opinion on Stellantis’ case involving TP adjustments and VAT.

Practitioners told me throughout to expect the IRS to reduce its load of new cases after seeing its resources slashed in 2025, and to focus its diminished capacity on bigger cases.

But first, it will have to wade ...