IRS Says Periodic-Adjustment Memo Continues Arising in Audits

June 3, 2026, 10:34 PM UTC

An IRS legal memo on the agency’s ability to adjust a company’s profits continues to come up in audits of companies’ transfer pricing, an IRS official said Wednesday.

“It’s not a one-off,” said James Kelly, deputy associate chief counsel for international, after speaking on a panel at a Texas Federal Tax Institute conference in San Antonio. “The issue is being evaluated for taxpayers under audit.”

The January 2025 generic legal advice memo, known as a GLAM, strengthened the IRS’s ability to use the commensurate-with-income standard to assert periodic adjustments when actual profits from transferred intangibles like intellectual property turn out ...

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