Internal Revenue Code Sections 6038 and 6038A impose on the U.S. owners of certain foreign corporations and partnerships and certain U.S. corporations that have significant foreign ownership the responsibility to file extensive and difficult tax forms Forms 5471 and 5472 disclosing transactions of these corporations and any related parties.  Non compliance with these filing requirements results in a penalty of $10,000 per failure to comply.

            Forms 5471 and 5472 are the primary tools the IRS uses to determine whether companies with international ties are setting fair and realistic prices for the goods and services provided to related parties or are taking advantage of the related party to distort and under report taxable profits through a tax evasion scheme involving Transfer Pricing. As a backstop to the Forms 5471 and 5472, the IRS requires these companies to gather proof that the prices they use for related parties sales are fairly set with respect to market prices.  The proof must take the form of a Transfer Pricing Study and must be done not later than the time at which the company files its annual tax return (a Contemporaneous Transfer Pricing Study).  Paul Wigg-Maxwell has extensive experience assisting in the preparation of these returns and studies and in dealing with audits and examinations of both.

            In 1990, Mr. Wigg-Maxwell was involved in one of the largest transfer pricing cases of that period.  He worked full time with a team of attorneys, economist, accountants and other professionals for more than a year on the matter as it went through Appeals, the Tax Court and was moved to a Competent Authority proceeding. The case involved a wide range of goods and many complex issues.

            Since 1990, Mr. Wigg-Maxwell has worked with clients to limit Transfer Pricing exposure and to satisfy compliance requirements including drafting contemporaneous transfer pricing studies, competing forms 5471 and 5472, defending companies against penalties for late filing or failure to file forms 5471 and 5472, planning compliance procedures.

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Oded Hecht
Very good experience. I had some uncommon and large financial situations abroad as a US Citizen. I just wanted to make sure I am going about it legally and wisely. I am a business executive (Harvard B. School), having interacted with many top lawyers worldwide, and working with Paul was a pleasure and a wise choice. Beyond helping me professionally to solidify a winning strategy through his sound knowledge and experience, the interaction was exceptionally forthcoming and pleasant. I would recommend Paul without any hesitation!
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Maria Alexander
Paul is an excellent attorney for small business owners like myself. He will make the appropriate research and make sure that the documents I have are all in working order and official. Paul always responds to phone my calls immediately, and he works fast whenever I need to have documents prepared quickly. His knowledge has helped me steer my business in the right direction and his advice is always on point and concise. I’ve had the pleasure of using Paul’s services for nearly a decade. During this time I had help with drafting and reviewing the following: several lease contracts, employee contracts, confidentiality and non-disclosure agreements, new client contract/liability waivers, US copyright electronic registrations, independent contractor agreements, website disclosure language, video release forms, and business registrations with the state. Having Paul as an attorney and being able to reach out to him whenever I have an emergency makes me more confident to run my business and I know that if I have a legal problem Paul will be there to help me.
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mathew gajewski
Cool guy, extremely nice and knows his stuff.
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Dan Trolaro
Took the time to listen, ask good questions, and provide good thoughts during initial phone call. Highly recommend giving him a call.
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Mr. Wigg-Maxwell helped me out with a complicated international inheritance tax question. He was quick to respond with a knowledgeable answer. I would happily bring any future tax issues I have to Mr. Wigg-Maxwell for resolution.


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17 Watchung Ave, Suite 203
Chatham NJ, 07928
Phone: 973 - 507 - 9760
Fax: 973 - 559 - 6330

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