- Identify recent shifts in IRS enforcement of transfer pricing rules, including the imposition of penalties and the impact on ASC 740 financial reporting requirements. - Recognize essential documentation practices that support transfer pricing compliance and help mitigate exposure to significant IRS penalties under IRC Section 6662. - Distinguish how tariffs and transfer pricing interact in cross-border transactions and assess the implications for import valuation and taxable income. - Estimate the financial risks of transfer pricing disputes, including penalties and shareholder impacts, and formulate early-stage strategies for mitigating exposure.