Official Cause of Fire: Transfer Pricing

Steps to monetize fire insurance policies:

1. conveniently forget to clean chimney for no less than five years
2. find the largest softwood tree in the back yard (ideally profusely sweating sap)
3. cut tree into 3 foot segments or largest size that can fit into the fireplace
4. pour accelerant on aforementioned lumber – lighter fluid is preferred
5. leave indoor bonfire unattended for no less than 20 minutes
6. call fire department and verify insurance.

To my would-be arsonists – please don’t intentionally follow my suggested path to anarchy – obviously, the first step should be checking your insurance policy.  According to the National Fire Protection Association (NFPA) only 8% of U.S. home structure fires were considered arson – the remaining 92% represent unintentionally caused fires.  Fire protection agencies aim to reduce this staggering 92% statistic by educating the public on eliminating unnecessary fire risks throughout the home.

This may come as a surprise considering my day job as a risk adverse, paper pushing, pocket protecting CPA, but the dashing firefighter in this mantel trophy is yours truly. Over my ten plus years as a firefighter, I’ve witnessed people take accidental shortcuts that ultimately turn into catastrophes. As an outside tax advisor, I’ve seen the same thing happen with careers.

Often times the catalyst of such self-ignited professional incinerations centers on the lack of proper documentation. And nothing is more vital than proper documentation in connection with transfer pricing. As a result of increased staffing, the Large Business and International (LB&I) division of the IRS now includes approximately 650 International Examiners all primed and ready to cover your desk with Information Document Requests (IDRs). If you are a multinational organization with cross border transactions, expect one of the adorning IDRs to request transfer pricing documentation.

Should you not be able to provide supporting transfer pricing documentation within 30 days of request, the IRS has the authority to adjust the value of the transactions to an amount the commissioner deems appropriate. Tax professionals who value their careers, shy away from giving the IRS such broad based power. The ability to produce contemporaneous transfer pricing documentation allows you to be prepared and confident in front of the IRS. Additionally, defending current transfer pricing positions with concise documentation helps companies escape large IRS adjustments and unforgiving underpayment penalties.

An office tastefully decorated like an exploded snow globe can create fire hazards. If a small spark from a hot LB&I examiner falls onto reams of unorganized transfer pricing documentation, you may find yourself in the middle of a wildfire that can’t be fought. Throw in an accelerant like underpayment penalties from lack of substantiation, and you have an inferno capable of cremating your career.

CCH Global Integrator has the ability to organize your transfer pricing documentation into a package free of fire hazards, giving you contemporaneous documentation suitable to put out the IRS flames. In addition, CCH Global Integrator has the ability to monitor cross-jurisdictional company compliance with internal transfer pricing policies, thus providing an extra level of comfort worldwide. Don’t get caught in the middle of a fire – call on CCH Global Integrator to be your company’s fire marshal and usher you through to safety.  To learn more please visit CCHIntegrator.com or call 800-678-2315.

Be certain to also read other value added articles from Chris Tump including: Lessons from the NFL Lockout – Don’t get Flagged for Excessive Excel®-ebration and Speedos and Margaritas – A Guide to Preparing Your Tax Return in the Fast Lane.