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Many issues involving international tax disputes were addressed at an invitational conference on transfer pricing sponsored by the Canadian Tax Foundation. All involved agreed that there was a need for international cooperation on the issue and voiced a desire to see the establishment of some mechanism that would make it faster and more economical to resolve transfer pricing disputes. Issues discussed include safe harbor, information requirements, expense allocation, cost-sharing, intangibles and arms length accounting.

The international panel sessions of the ABA Tax Section's May meetings focused on cost-sharing arrangements and nonresident alien withholding regulations, cross-border Internet sales, and bilateral advance pricing agreements. International philanthropy and tax arbitrage financial transactions were also discussed. Several panels, particularly the financial transactions and Tax Treaties Committee meetings, illustrated the difficulty in creating consistent international tax policy.

It is a commonly held belief that foreign owned corporations doing business in the US are not paying their fair share of taxes. Internal Revenue Code section 482 seeks to change this by giving the Secretary of Treasury more power to redetermine the amount of taxes such companies owe the US. Currently, a transfer pricing method which allows multinational corporations to doctor their books in order to allocate most of their income to a country with low tax rates may indeed be costing the US billions in tax revenue.