Administrations Fiscal Year 1994 Budget Proposals for the Bureau of Alcohol to

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Administrations Fiscal Year 1994 Budget Proposals for the Bureau of Alcohol to
United States Congress House Committee On Ways
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iv. Does IRS need help from Congress to provide confidentiality protections for third-party data?
The issue of third party comparable information highlights the conflict that may arise between important policy concerns as a result of our transfer pricing rules. The answer to your question depends on the manner in which the conflict between these competing policy concerns is resolved.
As referred to above in the response to part (i) of this question, third party comparable information (broadly d
...efined) is critical in the Service's ability to successfully apply the arm's length standard to determine the proper tax liability of an unrelated taxpayer. However, there are legitimate competing concerns about protecting the confidentiality of sensitive information obtained from unrelated third parties and preventing the imposition of undue burdens on such third parties (including U. S. Persons) .
To the extent that access to third-party comparables is deemed necessary and desirable in some cases, current law would almost certainly be insufficient to allow us to make reasonable accommodation for privacy concerns in every case.


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