Ideal Tax Solution, LLC Has Learned The IRS Is Soliciting Public Comments On Certain Transfer Pricing Issues

Share Article

Ideal Tax Solution, LLC is informing its clients and concerned taxpayers about the Internal Revenue Service interest in developing a ‘model memorandum of understanding’ between Competent Authorities on specific pricing issues.

Personal Touch

Understanding the specifics of the tax code is the foundation of our ability to help our tax liability clients.

Ideal Tax Solution, LLC is diligently collecting data on IRS plans to establish viable support for mandating sound tax administration in regard to ‘arm’s length compensation for routine distribution functions’. Routine distribution situations frequently arise as an issue in transfer pricing cases.

The IRS is requesting ‘highly’ specific comments related to the issues at hand, including input which speaks to putting forth text on ‘draft model agreements’ involving routine distribution functions. Ideal Tax Solution has learned the tax model would address the issue of Bilateral Safe Harbors, which refers to individuals and families who pay (or should pay) quarterly estimated taxes.

As a rule, if an individual or company doesn’t pay enough taxes to the IRS, they will be assessed interest and payment penalties. The Safe Harbor rule ensures the IRS can’t charge penalties as long as the amount a taxpayer pays in a current years is as much as what was paid in the previous year. The tax specialists at Ideal Tax Solution are experts at interpreting the appropriate use of the Safe Harbor Rule.

“The Safe Harbor Rule is just one aspect of professional tax resolution that we encounter on a regular basis,” says Sam Price, senior tax analyst at Ideal Tax Solution. “Understanding the specifics of the IRS tax code is the foundation for our ability to help our tax liability clients.”

The Organization for Economic Co-operation and Development (OECD) issued a discussion draft on Safe Harbors on June 6, 2012. The draft included sample memoranda of understanding on certain “low risk” functions. Ideal Tax Solution encourages public participation in any procedural changes being considered by the IRS.

For people interested in submitting comments greater than six pages in length, mail six copies to the following address:

    Internal Revenue Service
    Advance Pricing and Mutual Agreement Program
    1111 Constitution Ave., NW
    Washington, DC 20224

For U.S. taxpayers interested in finding out more about Ideal Tax Solution and their full range of in-depth and personalized tax preparation services, or for any tax help related issue, visit them online at You can also reach them by phone by dialing 888.393.5154. Good tax tips and additional information can be found on their Facebook page and by following them on Twitter.

About Ideal Tax Solution, LLC – Located in Costa Mesa, California, the company provides a full range of tax preparation and resolution services as well as reassurance to taxpayers nationwide. With more than 55 years of combined experience providing American taxpayers with federal and state income tax solutions, Ideal Tax Solution offers an experienced staff which includes Enrolled Agents, CPAs and Senior Tax Consultants who stand at the ready to help with any tax issues.

Share article on social media or email:

View article via:

Pdf Print

Contact Author

Gary Sweet
Visit website