You are newly employed as the global Transfer pricing manager of a large U.S. multinational corporation with the global Head Office in New York. The corporation has a complex structure with subsidiaries in many countries. The US Parent, Parent Co, has the following wholly owned subsidiaries:

UK Co

Newco Cayman Island

Brussel Co

France Co

Vietnam Co

South Korea Co

The Parent Co and its wholly owned subsidiaries constitute the Multinational Group.

As you start your job several challenges cross your desk that require your attention.

The IRS is auditing your US intercompany transactions.The IRS has been auditing for nearly a year and the statute is about to run.The IRS examiner has spoken with you about transfer pricing.However, his last comment was:

"We will make an adjustment for 1 million USD, because we need to close this case. If you do not accept our adjustment, we will be on your neck for the next 5-7 years".

1. What is your dispute resolution strategy to resolve the matter?(keep it short and to the point)