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U.S. officials are urging taxpayers to provide detailed commentary on the Organization for Economic Cooperation and Development's action plan to combat base erosion and profit shifting (BEPS), particularly on the issue of hard-to-value transactions.
Working Party No. 6 of the OECD, which is charged with addressing transfer pricing issues, is still in a “brainstorming phase” for BEPS, said Brian Jenn, attorney adviser in the Treasury Department's Office of the International Tax Counsel.
“This is really the right time for business to come in and present to us actual detailed options that we can evaluate and discuss in comparison to other options that you might not like as much,” Jenn said Dec. 12 at the 26th Annual Institute on Current Issues in International Taxation co-sponsored by George Washington University Law School and the Internal Revenue Service.
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