Many years ago, a crack unit of specialists from Big Four audit firms and boutique consultancy firms – were working on the mean streets of Broadway to South Street on the East River in Lower Manhattan. These men promptly escaped from the financial district to the nation’s capital. Today, they are wanted by the government. As in really wanted by the government. The IRS is recruiting high-powered talent, the big guns, in their efforts to crack down on companies shifting profits overseas to avoid federal taxes. If there is a problem, if no one else can help, and if the IRS can find them, maybe they can hire them…

It sounds like something out of a TV show. It has all of the elements: intrigue, drama, international waters, and now, an elite team hired to come in and change the world. Or at least that’s the plan.

The IRS has, in the past few months, significantly ramped up its emphasis on transfer pricing enforcement. Transfer pricing is a tricky concept affecting multinational corporations. In a typical scenario, a parent company may set up several subsidiary companies all over the world and move goods, services, and assets from one to another. Those transactions are supposed to be “arm’s length,” meaning that the goods, services, and assets are transferred for the same price as they would have between unrelated parties. But that’s not what happens. With a wink and a nudge, transactions are structured to shift profits from high tax countries (like the U.S.) to low tax countries (like Ireland) to cut their tax bills.

Many countries have been making noise in an effort to curb transfer pricing abuse, but the US has, until recently, remained oddly silent. In fact, the US has been content for years to allow other countries and organizations like the Organization for Economic Cooperation and Development, or OECD, which issued a report on Transfer Pricing Simplification Measures in June of 2011 (note that it opens as a large pdf), to take the lead.

Now, the US is finally causing a stir by putting together its own A Team, an elite group of tax specialists. The IRS showed its commitment last year by hiring Samuel “Face” Maruca to serve in the newly created position of transfer pricing director. Maruca is a highly respected tax attorney originally from the law firm of Covington & Burling. His job at IRS is to recruit the private sector’s top talent for the IRS’ mission.

Maruca will report directly to the Large and Mid-Size Business Division Deputy Commissioner, Mike “Hannibal” Danilack. Danilack comes to the IRS from Burt, Staples and Maner, LLP, a law firm that specializes in international tax law. Prior to this, he worked as a principal at Deloitte Tax, LLP, focusing on cross-border tax matters.

The team’s pilot is John “Howling Mad” Hinding, who is the Director of the Office of Associate Chief Counsel, Advance Pricing Agreement (APA) Program. Hinding drives the APA program which will shift from the office of IRS Chief Counsel to an office under Maruca.

Bringing the muscle is Doug “Bad Attitude” Shulman, whose plans tend to be unorthodox but effective. As the current IRS Commissioner, Shulman has been quietly making changes that would serve as the backdrop for this new crack team.

And who is in the team’s sights? A number of multinational companies. Tops on the list are those in the pharmaceutical and high-tech sectors, the same ones (like Apple, Microsoft, Oracle, and Pfizer) setting up shop overseas in such garden spots as Ireland, the Netherlands, and the Caymans.

Will the team be a success? Most tax professionals, myself included, tend to think that it’s going to be an uphill battle for IRS. After all, there are billions and billions of dollars at stake.

But the IRS might have a little wind in its sails. Last year, IRS settled a transfer pricing case with Western Union for $1.2 billion (yes, with a b); prior to that, the IRS had not made significant transfer pricing enforcement news since 2006 when it settled with GlaxoSmith Kline for $3.4 billion (also with a b). But two huge wins in the space of five years might be enough to give the IRS the confidence it needs to chase more companies (it’s reminiscent of the strategy with banking secrecy issues and UBS).

To make a statement, though, IRS will have to bring more bodies on board for enforcement. With the acquisition of Maruca, forty positions have been filled as of yet and the IRS has plans for more new hires, despite an agency budget crunch.  Those who have already joined the task force include professionals from such firms as KPMG and Ernst & Young and law firms like Mayer Brown and Horst Frisch.

So what’s bringing the top talent to IRS? A commitment to justice? A desire to make a difference? An obsession with transfer pricing? Maybe.

Or maybe it’s the economy. As private sector jobs dry up – or turn out to be not as swell as advertised – a steady government job now has more appeal than it did before. That’s how Maruca has been able to fill 40 of the nearly 60 positions available on his squad even in a climate when the IRS budget is meager.

This new talent has been, for years, toiling on the other side, working for the opposition. Now, the group, a virtual tax law dream team, is being called, in some circles, an IRS SWAT team. Whether the IRS is bringing Special Weapons and Tactics remains to be seen – but they are clearly bringing their A Team.

And c’mon, you know you’re thinking it, so say it with me: I love it when a plan comes together.

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Kelly Erb is a tax attorney, tax writer and podcaster.

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