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Abstract
Sam Maruca, the IRS's first-ever transfer pricing director, said his aims for his time in office were to improve the organisation's transfer pricing process. While no one could be accused of disagreeing with his goals, to improve enforcement, resources, skills and to focus on intangibles, transfer pricing practitioners think the new director could be banging his head against a brick wall because of the structure of the IRS. Since the mid-1950s, the IRS has been a decentralised organisation, to combat bribery. Transfer pricing cases are developed by the administrators in the field office and they don't report to Maruca. Maruca can provide the guidance about what kind of cases should be developed, but ultimately it's the field agents and economists that decide. Litigating them is the field lawyers and the National Office (Chief Counsel's Office).