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Transfer Pricing · Insights

Transfer Pricing insights

Plain-English tax guidance on transfer pricing from our CPAs and Enrolled Agents.

Explore Transfer Pricing
Individual Tax PreparationBusiness & Corporate TaxTax Planning & StrategyBusiness Tax CreditsIRS Audit DefenseTax Debt ResolutionInternational TaxState & Local Tax (SALT)Estate Income TaxFlorida 1031 ExchangeNonprofit Tax ServicesExpats / Expatriate TaxTax Court RepresentationFederal TaxTax Risk ServicesTransfer PricingTax ComplianceUS Inbound TaxM&A TaxIRS Tax AdvocateOutbound TaxTax Treaty PlanningFIRPTA & Foreign Real EstateForeign Business Expansion
Transfer Pricing Documentation: How to Avoid §6662(e) Penalties
Transfer Pricing
Mar 9, 2026·6 min read

Transfer Pricing Documentation: How to Avoid §6662(e) Penalties

Contemporaneous transfer-pricing documentation is your shield against 20%–40% §6662(e) penalties. Here's what the master file / local file model requires and where Form 5472 fits in.

SMAART Tax Team
The Arm's-Length Principle: Transfer Pricing Methods in Plain English
Transfer Pricing
Feb 24, 2026·6 min read

The Arm's-Length Principle: Transfer Pricing Methods in Plain English

The arm's-length principle is the core test behind every transfer-pricing rule. Here are the five main methods — CUP, resale-price, cost-plus, TNMM, and profit-split — explained without the jargon.

SMAART Tax Team
Transfer Pricing 101: Why the IRS Cares About Your Intercompany Deals
Transfer Pricing
Feb 10, 2026·6 min read

Transfer Pricing 101: Why the IRS Cares About Your Intercompany Deals

If your business has a related entity in another country, the price you charge yourself is an IRS matter. IRC §482 lets the IRS re-price intercompany transactions — and the adjustments are expensive.

SMAART Tax Team

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