John Warner, shareholder in the firm's Tax section, comments on new requirements that IRS examiners conducting transfer pricing audits consult with Advance Pricing and Mutual Agreement program personnel in Law360 Tax Authority's article "Changes to IRS Audit Process Anticipate Foreign Disputes."

John Warner of Buchanan Ingersoll & Rooney PC, another longtime transfer pricing specialist, said the change was probably long overdue. The IRS "understandably doesn't want to have to try to defend adjustments proposed by [IRS examiners] that [it] knows are going to be hard to defend in a competent authority proceeding," he said.