Planning intercompany transfer pricing and protecting planning documents - the Bell case

Article Abstract:

The possibility under the transfer pricing penalty provisions of IRC section 6662 for disclosure of transfer pricing documents dictates that taxpayers involved in such transactions take steps to ensure that such documents will fall under the work product doctrine or attorney-client privilege. Problems often arise, as they did in United States v. Bell, when a third party, such as an accountant, is retained. The attorney, not the taxpayer, should retain the third party, the party should be informed that litigation is likely and all privileged documents should be so marked.

United States, Planning, Laws, regulations and rules, Discovery (Law), Transfer pricing, Tax penalties, Work product privilege (Law), Related party transactions

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NAR board backs stronger Code of Ethics enforcement

Article Abstract:

A wide array of association initiatives that are designed to promote a stronger business climate for NAR members was approved by the organization's board of directors. One of the initiatives is improvement in the implementation of Code of Ethics.

Standards, Real estate industry, Ethical aspects, Business ethics, National Association of Realtors

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