International Taxation: IRS' Administration of Tax-Customs Valuation Rules in Tax Code Section 1059A

Pursuant to a congressional request, GAO provided information on the Internal Revenue Service's (IRS) enforcement of section 1059A of the Internal Revenue Code (IRC), focusing on: (1) specific cases in which IRS used section 1059A to govern transfer prices; (2) the applicability of section 1059A to certain transactions between U.S. and Mexican affiliates; (3) the impact on U.S. revenues of allowing U.S. taxpayers to make payments on behalf of their foreign-related parties; and (4) legislative proposals to reconcile IRS and the Customs Service's valuation rules.