Transfer pricing is a significant area of concern for taxing authorities and multinational entities (MNE). Examine at least two (2) potential transfer pricing issues that create concern for both Internal Revenue Service (IRS) and MNEs, and provide an example that demonstrates the effects of the issues.
According to the textbook, the arm’s length standard is used globally to prevent double taxation and resolve transfer pricing disputes. Recommend at least two (2) procedures you would propose as the tax manager of an MNE to reduce the audit potential for transfer pricing issues by the IRS. Provide examples to support the expected impact of your recommendations