US Mulls Expanding Reach of Simplified Transfer Pricing Rules (1)

The IRS is contemplating expanding draft regulations on a new, simplified transfer pricing method to include certain kinds of digital transactions, such as the distribution of copyrighted articles, an agency official said Thursday.

The US is doing “a lot of brainstorming” about the reach of proposed regulations that detail how corporate taxpayers can apply a framework called Amount B, according to Zeb Kelley, chief of Branch 6 of the IRS Office of Associate Chief Counsel, International. He was speaking at the 2026 DC Bar Tax Conference.

“Do we want to limit the ...