United States Government Publishing Office publisher pbl distributor dst United States Government Accountability Office General Government Division author aut Government Organization text government publication eng GAOREPORTS Legislative Agency Publications gao legislative 2010-08-12 U.S. Government Printing Office 1994-02-04 monographic deposited born digital GA 1.13:GGD-94-61 https://www.govinfo.gov/app/details/GAOREPORTS-GGD-94-61 P0b002ee180395477 f:gg94061 DGPO 2010-08-12 2011-03-23 GAOREPORTS-GGD-94-61 machine generated eng fdlp REPORT GAOREPORTS-GGD-94-61 GGD-94-61 Customs administration Tax administration International economic relations International trade regulation Foreign corporations Income taxes Tariffs Investments abroad Underpayments Tax law North American Free Trade Agreement NAFTA Mexico Mexican Maquiladora Program Letter Report GGD

This report provides information on the Internal Revenue Service's (IRS) enforcement of section 1059A of the Internal Revenue Code, which deals with transfer pricing regulations. Section 1059A was meant to prevent the federal government from being whipsawed by an importer, on property acquired from a related party, who claims a low valuation for customs purposes and a higher valuation for tax purposes. GAO discusses IRS' difficulties in applying the section and a July 1992 IRS legal opinion on the applicability of section 1059A to transactions between a U.S. parent firm and its Mexican related parties. GAO also discusses proposals to reconcile differing IRS and U.S. Customs Service valuation rules that affect the use of section 1059A. https://www.govinfo.gov/content/pkg/GAOREPORTS-GGD-94-61/html/GAOREPORTS-GGD-94-61.htm GAO/GGD-94-61 https://www.govinfo.gov/app/details/GAOREPORTS-GGD-94-61 Letter Report GAO/GGD-94-61; International Taxation: IRS' Administration of Tax-Customs Valuation Rules in Tax Code Section 1059A; Customs administration Tax administration International economic relations International trade regulation Foreign corporations Income taxes Tariffs Investments abroad Underpayments Tax law North American Free Trade Agreement NAFTA Mexico Mexican Maquiladora Program Title 19 Section 1401a(b) Title 19 Section 1401a(e)(1) Title 19 Section 1401a(h)(1) 19 U.S.C. 1401a(b) 19 U.S.C. 1401a(e)(1) 19 U.S.C. 1401a(h)(1)