A slew of big tax disputes and the worldwide upheaval brought on by the Trump administration's aggressive trade policy made for an exceptionally interesting year for transfer pricing professionals, and left them with lingering questions heading into 2026.

President Donald Trump's April tariff announcements sent shock waves through the global economy and forced corporate tax heads—and C suites—to start figuring out what it all meant for their tax and transfer pricing positions, and whether they needed to make changes to fend off potential audits.

At the same time, companies are seeing a growing number of audits and transfer pricing disputes—often with big dollar figures—as tax authorities around the world beef up their auditing and enforcement capabilities with staff, AI, and stronger reporting requirements. Auditing multinationals can bring them big tax rewards.

That might be less true at the IRS, where the Trump administration has drastically reduced resources and staffing.

On this episode of Talking Tax, Bloomberg Tax transfer pricing reporter Caleb Harshberger discusses what's been going on in the world of transfer pricing—which governs transactions within corporate groups—and what he's keeping an eye out for next year.

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Anyone thinking about pushing the boundaries of tax law should remember that there's no federal statute of limitations on prosecuting fraud, even with weakened IRS enforcement, said Carolyn Schenck, who spent 20 years at the agency primarily combating tax evasion.

"If people think that a current administration or a past administration might go soft on tax fraud, that's still an awfully big gamble," said Schenck, who's now at Caplin & Drysdale. "And I know that that's not one I personally would want to take."

The IRS is coming off a tumultuous year with deep staffing cuts from the Trump administration's efforts to downsize the federal government and a parade of new commissioners. But increasing IRS staff and resources would be one of the best ways the government could combat fraud and collect more of the money it's owed, Schenck said.

On this episode of Talking Tax, Schenck sat down with Bloomberg Tax reporter Erin Schilling to discuss what Trump administration workforce cuts mean for IRS enforcement and how the agency could improve its efforts to go after illegal tax shelters, even with a diminished staff.

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For the holidays, we serve up an encore presentation of a Talking Tax podcast that shows cross-border tax fraud has been around a long time.

When researchers studied a previously mislabeled scroll, they discovered detailed attorney notes for a case against taxpayers accused of using forged documents and sham transactions between the Roman provinces of Judaea and Arabia to escape taxes on their assets. The assets in question were enslaved people. The potential punishments included distinctly unmodern measures.

Anna Dolganov of the Austrian Academy of Sciences talked with reporter Caleb Harshberger about how scholars made the discovery, details of the scheme, and what they’re hoping to uncover next as they continue their research.

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Congress is back after ending the longest shutdown in US history. But the bipartisan accord left funding for the IRS and Treasury Department ending in less than three months and the fate of the enhanced premium tax credits at the center of the crisis still unresolved.

On this episode of Talking Tax, Bloomberg Tax Congress reporter Zach C. Cohen and Bloomberg Government health policy reporter Erin Durkin discuss next steps for appropriating funds for the IRS and Treasury after current funding runs dry Jan. 30, and potential legislative solutions to rising health-care premiums.

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New York City Mayor-elect Zohran Mamdani ran on an expansive affordability agenda that would be paid for by higher taxes on corporations and wealthy individuals.

The democratic socialist's vision will be tough to realize, though, because any tax hikes would have to be approved by the New York State legislature and tax hike-averse Gov. Kathy Hochul (D). Local tax practitioners are emphasizing this political reality to worried clients who called and emailed in a hurry after Mandani won the Nov. 4 mayoral contest.

“There’s been kind of some demystifying as to how can or how will the mayor be able to make these ideas or proposals law," Jeremy Gove, a state and local tax counsel at Eversheds Sutherland, tells Bloomberg Tax editor Benjamin Freed on this week's episode of the Talking Tax podcast. "Explaining this to taxpayers is what we’ve been tackling over the past week or so.”

Gove says that while higher taxes could compel some New York companies and wealthy individuals to decamp for lower-tax states, there's also a "wait and see" sentiment prevailing. Taxpayers might even welcome some proposals from Mamdani, such as hiring more auditors to clear out the Department of Finance's hefty case backlog, he says.

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Grant Thornton’s top audit leader is bullish on the practice’s future after a 2024 deal that sold a significant stake in the accounting and advisory firm to private equity investors led by New Mountain Capital.

The audit practice has benefited from a boost in dedicated resources and also bolstered its safeguards against conflicts of interest. Those improvements stem from an operating contract between Grant Thornton’s legacy audit practice and its PE-backed business, said Ron Messenger, CEO of Grant Thornton’s audit business.

The firm’s private equity deal ushered in a new two-part legal structure that created a corporate entity to provide its tax and advisory work while audit partners run the firm’s legacy assurance business. Nearly half of the largest 30 firms have cut PE deals and they all rely on what the industry calls the “alternative practice structure.”

Underpinning that new operating structure is a services agreement spelling out the relationship between the two entities from governance to resources.

Those agreements can’t be an afterthought, Messenger said. He spoke with Bloomberg Tax reporter Amanda Iacone about how Grant Thornton's services agreement came together, how regulators informed that document, and how it will influence the quality of the firm’s auditing.

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A Trump administration push to reduce the frequency of corporate earnings reports risks hurting the accuracy of artificial intelligence-fueled models used by analysts, an accounting adviser said.

Chief financial officers and other C-suite leaders would in turn need to address greater reputational risk if a plan to give public companies the option to file financial reports semiannually instead of quarterly advances, according to Steve Soter, vice president and industry principal at financial compliance platform Workiva.

Companies prepare and submit quarterly reports, called Form 10-Qs, to the Securities and Exchange Commission's filing system in XBRL format, which makes the information more easily accessible and computer-readable, Soter said. Analysts' models consume this data to provide analysis and observations.

Depriving investors and analysts' AI models of this information increases the risk of erroneous analysis and ensuing reputational damage, Soter said.

On this episode of Talking Tax, Bloomberg Tax financial accounting reporter Jorja Siemons spoke with Soter about what steps C-suite leaders can take to mitigate data risks if the SEC reporting schedule shifts.

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Despite the ongoing US government shutdown, many at the Treasury Department remain on the job working on guidance related to the July GOP tax law.

Those at Treasury handling the international provisions used to be coworkers of Beth Bell, who became a principal at PwC’s National Tax Service in Washington less than a month ago.

On this week's episode of Talking Tax, Bell sat down with Bloomberg Tax senior reporter Chris Cioffi to discuss US efforts to secure agreements to allow the US tax system to coexist with the Pillar Two project, and what might prompt Republicans in Congress to reintroduce what came to be known as the "revenge tax" when the law was debated.

Bell has deep experience with multilateral tax negotiations and worked as a staffer in both the House and Senate, playing a role in major tax legislation that passed in both the Biden and Trump administrations.

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Ireland has presented a frugal budget for 2026 in the face of uncertainties caused by President Donald Trump's tariff and tax policies.

The 15% global minimum tax on corporations and Trump's threats to impose large tariffs on pharmaceutical companies—most of which are US companies headquartered in Ireland—have increased pressure on the country to find ways to remain competitive.

With foreign-owned multinationals in Ireland paying the majority of the country's corporation tax, the government is mulling incentives to encourage them to stay.

In this episode of Talking Tax, Bloomberg Tax reporter Ryan Hogg discusses some options the government is considering, including an increase in the R&D tax credit.

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Taxpayer advocates are keeping close watch on this week's decision to name Social Security Administration Commissioner Frank Bisignano as CEO of the IRS, and have many questions about what it could mean for the agency.

Treasury Secretary Scott Bessent said Monday he was creating a new IRS CEO position, and Republicans in Congress seem to be generally supportive, though some said the White House should still name an IRS commissioner nominee. The Treasury Department assured staff in GOP Iowa Sen. Chuck Grassley's office that a commissioner nominee would still be sent to the Senate.

At the same time, the Senate Finance Committee voted Wednesday to advance Derek Theurer's nomination to be undersecretary for legislative affairs and Donald Korb's nomination to be IRS chief counsel.

That's good news for Pete Sepp —president of the National Taxpayers Union, a taxpayer advocacy group—who is concerned that many of the top IRS positions remained unfilled.

Sepp, who sat down with Bloomberg Tax Senior Reporter Chris Cioffi for this episode of Talking Tax, said Congress is right to seek answers about how the CEO job interacts with the commissioner. He said he hoped the CEO position, in the future, would be selected by an IRS oversight board that has been dormant for more than a decade.

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