Contract analysis

I. Background and Examination Status The current examination was opened on May 16, 2022, upon PPC's receipt of IRS Letter 2205-A, notifying the Company that its federal income tax returns (Forms 1120) for tax years 2017, 2018, 2019, and 2020 had been selected for examination. The examination is being conducted by the Large Business & International Division, Northeast Compliance, Transfer Pricing Practice, under Exam

II. Summary of IDR Activity and Cooperation to Date Since the examination was opened in May 2022, the examination team has issued a substantial and growing number of Information Document Requests. As of the date of this letter, PPC has received and responded to well over thirty IDRs, and the process of IDR issuance and response has been ongoing and intensive throughout the past eleven months. PPC has responded to eac

III. Request for Conference — Specific Objectives PPC respectfully requests that the mid-examination conference address the following four objectives, each of which is described in greater detail below. A. Objective 1: Clarify the Scope of Remaining Issues As a threshold matter, PPC requests that the examination team identify which transfer pricing issues remain under active consideration and which, if any, issues th

IV. Proposed Conference Logistics PPC proposes that the mid-examination conference take place at a mutually convenient date in late May or early June 2023. We recognize that scheduling may be subject to the availability of multiple participants and are prepared to be flexible in accommodating the examination team's preferences. PPC proposes the following attendees on behalf of the taxpayer: • Leonard Cross, Partner,

V. Statute of Limitations Acknowledgment PPC acknowledges that it has cooperated with the examination team's requests to extend the statute of limitations on assessment as needed to facilitate the orderly conduct of the examination. Specifically, PPC has executed Form 872, Consent to Extend the Time to Assess Tax, with respect to tax years 2017 and 2018, extending the applicable assessment periods to dates agreed upo

VI. Conclusion PPC reiterates its commitment to a cooperative and efficient examination process. The Company has devoted substantial resources to the examination over the past eleven months and intends to continue its approach of full and timely cooperation with the examination team. PPC respectfully submits that a mid-examination conference at this stage of the examination will benefit all parties. Such a conference