Amendments to the IRS appraisal authority and tax-free reorganization rules
- Presumptions are established in favor of the taxpayer that the SII would have to distort in the process of inspection (e.g., transactions between unrelated parties, of publicly traded securities, sale of shares or rights in companies at the value of the proportional financial patrimony).
- Rules are established to determine values in intra-group operations. They will be reviewed under a comprehensive and consistent view, considering the effects for both parties of the operation.
- The evidence of the arm’s length value is regulated. The taxpayer may justify the price or value of an operation under any generally accepted valuation method.
- Cross-border mergers and international reorganizations, subject to certain requirements, are exempt from the IRS appraisal authority.