Barnes Dennig Transfer Pricing After Tax Reform and COVID-19 120920 - BD | Page 11

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WHAT IF THE IRS DISAGREES WITH TRANSFER PRICING ?

Assume a total transfer pricing tax adjustment of $ 10m

Additional income tax owed : $ 10m x 35 %* = $ 3.5m Plus non-deductible penalties of 20 % $ 700,000

$ 4.2M + interest + US state taxes + potential double tax

20 % penalties start at $ 5m , penalties increase to 40 % at $ 20m NO automatic refund of double tax

* Open tax years at pre-tax reform 35 % rate