This study uses a confidential data set of firms assigned to the Internal Revenue Service's Coordinated Industry Case (CIC) program to examine the effect of audit certainty on firms' tax reporting behavior. We first model the determinants of assignment to the program. Although the ability and incentive to avoid taxes are related to CIC assignment, we find that the IRS assigns firms primarily based on size and complexity. We then test whether audit certainty has a detectable effect on tax payments. Our results show that tax payments do not change when firms enter the CIC program, suggesting the CIC program does not have higher deterrence or enforcement effects relative to the IRS's standard selection and audit process for large corporations not included in the CIC program. However, supplemental analysis suggests that audit certainty does alter managers' expectations regarding future tax payments. Our paper provides new empirical evidence on the strategic game between the taxpayer and the tax authority and has important implications for tax authorities as they consider the costs and benefits of certain audit programs.

We interview public company tax executives to provide new evidence on how corporate taxpayers experience and navigate the income tax audit process. Interviewees describe being “targeted” by “tax police” and having to “defend” their positions. Thus, we adopt a structural metaphor of tax audits as police investigations and use a framework from the policing literature to explain what influences taxpayers' perceptions of fairness during audits. Perceptions of fairness are important as targets of investigations are more likely to cooperate and accept outcomes when they perceive policing processes as fair. Tax executives aim to obtain fair and consistent treatment by compiling documentation, consulting with peers and external advisors, and educating tax agents. Audits are adversarial, however, and taxpayers also act strategically to secure favorable outcomes and appeal or litigate when they believe outcomes are unfair. Interviewees note variation in the extent to which tax authorities create frameworks that facilitate fair audit processes and whether tax agents implement these frameworks. Our study offers new insights into the tax audit process from corporate taxpayers' perspectives. First, public company taxpayers view tax audits as redundant to financial statement audits of their tax positions. Thus, tax audits may have limited scope to deter tax noncompliance. Second, tax executives are not passive actors; they take deliberate actions to shape audit outcomes. Third, audits are less efficient for everyone when taxpayers perceive them as procedurally unfair. Investments by tax authorities that increase perceptions of fairness may enhance audit efficiency by increasing taxpayers' cooperation and acceptance of outcomes.

Our study evaluates the role of coordination, at both the government and the firm level, on the transfer prices set by U.S. multinational corporations ( MNC s) when income taxes and duties cannot be jointly minimized with a single transfer price. We find that either the presence of a coordinated income tax and customs enforcement regime or coordination between the income tax and customs functions alters transfer prices for these firms. Our analyses have implications for both firms and taxing authorities. Specifically, our findings suggest that MNC s might decrease their aggregate tax burdens by increasing coordination within the firm or that governments might increase their aggregate revenues by improving coordinating enforcement across taxing authorities. Our study is novel in that we document, in a specific setting, how coordination influences MNC s’ tax reporting behavior.