SRBI Report For IRS Survey Of International Business Entities
The IRS selected a national research firm, Schulman, Ronca and Bucuvalas, Inc. (SRBI) to conduct a confidential and voluntary survey of companies with cross-border transactions between related entities, concerning their preparation and use of contemporaneous documentation. SRBI conducted telephone interviews with the corporate CFO, heads of tax departments, finance offices or similar officials in 4,242 companies from a listing provided by the IRS. A total of 1,529 of these companies reported net gross receipts or sales over $10 million dollars on their most recently filed federal income tax return and cross-border transactions with related entities during the same period. A more detailed series of questions about the application of section 482 and the effects of section 6662(e) was completed on-line by the person responsible for documentation and records required for filing the company's taxes in 696 of these eligible companies (46%).

Fiscal Years 2000 - 2001 IRS Study - Effectiveness of Internal Revenue Code Section 6662(e) - Final Report