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Brendan Sponheimer

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Brendan Sponheimer is an associate in the New York office of Baker McKenzie and a member of the Tax Practice Group. Prior to joining the Firm, Brendan was a Tax Controversy and Transfer Pricing Associate in New York, and an Attorney Advisor for Judge Joseph Robert Goeke of the United States Tax Court in Washington, D.C.

The IRS is laying the groundwork for more aggressive and contentious transfer pricing controversies, recently revealing that it will more actively consider applying the economic substance doctrine and related penalties in those cases. It is unclear how the IRS would apply the doctrine to otherwise economically meaningful related party arrangements, but the IRS’s shot across the bow should be taken seriously, and the new approach will likely soon be made manifest at the examination stage.

Read publication We are pleased to enclose the February issue of Tax News and Developments, a publication of Baker McKenzie’s North America Tax Practice Group. This month’s edition features a discussion on three Tax Court opinions under section 6751 (b), final withholding regulations, a review of final and proposed BEAT…