Why Maruca’s goal to select high-risk transfer pricing cases for the IRS may be difficult to achieve
February 09, 2012
Sophie Ashley
Sam Maruca, the IRS’s transfer pricing director, said his highest priority was enforcement; to select the cases that need pursuing and to leave those that do not. One ex-IRS officer explains why this is easier said than done.
Maruca set out his goals in an interview with TPWeek towards the end of last year but Mike Patton of DLA Piper in California, who worked on the IRS side, in the Chief Counsel’s Office for 15 years, said while no one could disagree with his goal, the practicalities of the IRS structure mean this could be difficult in practice.
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