Tax Coda Weekly Digest — December 7, 2025
This week showed how quickly the ground can shift when institutions lose memory, when policy moves faster than staffing, and when courts slash valuations that never should have survived first review.
Guidance arrived in fragments, enforcement signaled uneven strength, and planning season reminded everyone that timing still solves problems better than hope.
The system felt busy but not steady.
1. Transfer Pricing Enters a New Era of Volatility and Scrutiny
We outlined how the transfer pricing landscape in 2025 has moved faster than the IRS can stabilize its teams. Enforcement whiplash, hiring freezes, and case selection swings have become part of the environment. Companies face more uncertainty, not because the rules changed, but because the enforcement posture keeps shifting.
Why It Matters:
Volatility affects documentation and audit strategy.
Reduced staffing does not eliminate exam risk.
Multinationals must plan for inconsistent enforcement.
Takeaway:
Transfer pricing is in motion, and stab…
