Last week, the IRS announced that it was realigning and renaming its Large and Mid-Size Business division, with a goal of creating a centralized organization better geared to international tax compliance. The new group will be known as the Large Business and International (LB&I) division. As part of the reorg, the agency's international examiners now will report up through this group. Along with the existing staff of 600, about 875 examiners who specialize in international tax matters within other departments of the IRS now will come under the LB&I umbrella. Mike Danilack, deputy commissioner of international, will head the new unit, which will focus on businesses with at least $10 million in assets.

The Obama administration’s 2011 budget includes many elements to disgruntle the average CFO or finance director, but few raise finance exec hackles at US multinationals as quickly as transfer pricing.

Budget proposals would require US corporations to pay tax immediately on returns of more than 30 percent traced to intangible assets owned by offshore subsidiaries in tax haven countries. The proposal sets an effective corporate tax rate threshold of 10 percent to identify tax haven jurisdictions.