Abstract

This article highlights the rules and practices in the United States concerning transfer pricing year-end adjustments including appropriate collateral adjustments such as correlative allocations, conforming adjustments and setoffs. In addition, this article discusses relevant audit procedures related to year-end adjustments in the United States and provides best practices for taxpayers to prevent potential disputes.The article is part of a special issue of the International Transfer Pricing Journal on transfer pricing end-of-year adjustments. The other articles include the General Report and contributions on Belgium, France, Germany, Ireland, Italy, Korea, the Netherlands, Spain and the United Kingdom.

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