U.K. Retaliation Predicted If Aggressive U.S. Enforcement of Intercompany Pricing Persists

On February 14, during a program of the Committee on International Tax, American Bar Association's Section of International Law, Jill Pagan, an attorney with J.F. Chown & Co., London, warned that, if the U.K. during the coming years continues to see its share of tax revenues diminished by U.S. tax changes that seek to extract increasing amounts from U.K. companies operating in the U.S., the U.K. could implement certain retaliatory measures relatively quickly that could result in increased burdens on U.S. companies' subsidiaries operating in the U.K.