Pages

▼
Showing posts with label Transfer Pricing. Show all posts
Showing posts with label Transfer Pricing. Show all posts
Thursday, November 9, 2023

Coca-Cola Tanks Again in the Last Round of Transfer Pricing Litigation in the Tax Court (11/9/23)

›
I have written before on Coca-Cola's massive transfer pricing case as the results dribbled out over the years (reverse chronological ord...
Saturday, August 27, 2022

Eaton Wins Big on Appeal in Long-Running Contentious Litigation Over APAs (8/27/22)

›
In Eaton Corp. v. United States , 47 F.4th 434 (6th Cir 8/25/22), here  and GS here , the Court gave Eaton a victory on all points of conten...
Saturday, August 20, 2022

Transfer Pricing: Finite Valuation and Ranges (8/20/22)

›
          I have just started reading a tax, more or less, history, at least anecdotal history. Michael Keen, & Joel Slemrod, Rebellion,...
Monday, November 23, 2020

More Coca-Cola - On Transfer Pricing and Blocked Income Regulation (11/23/20)

›
I recently wrote on burden of proof issues in The Coca-Cola Company v. Commissioner , 155 T.C. ___, No. 10 (2020), here .  Tax Court (Judge ...
Thursday, November 19, 2020

Tax Court (Judge Lauber) Issues Significant Transfer Pricing Decision in Coca-Cola; Burden of Proof Issues (11/19/20; 11/25/20)

›
Yesterday, the Tax Court decided The Coca-Cola Company v. Commissioner , 155 T.C. ___, No. 10 (2020), GS  here , a transfer pricing company ...
Tuesday, November 12, 2019

Altera Corp. Petition for Rehearing Denied (11/12/19)

›
I have written before about the cause célèbre that is the Altera case.  Altera Corp. v. Commissioner , 145 T.C. 91 (2015), here , rev'd ...
Saturday, August 31, 2019

Altera Petition for Rehearing and DOJ Tax Response in opposition in Altera Case (8/31/19)

›
I previously discussed the decision in Altera Corp. & Subsidiaries v. Commissioner , 926 F.3d 1061 (9th Cir. 2019), here , where the rec...
Sunday, August 18, 2019

Amazon Wins Transfer Pricing Dispute on Regulations Interpretation (8/18/19)

›
In  Amazon.com, Inc. v. Commissioner , ___ F.3d ___ (9th Cir. 2019),  here , a transfer pricing case, the Court held that, under the applica...
Friday, June 7, 2019

Ninth Circuit Reverses Unanimous Tax Court in Altera (6/7/19; 6/20/19; 7/2/19)

›
I have blogged on the Ninth Circuit's prior opinion reversing the unanimous Tax Court in Altera Corp. v. Commissioner , 145 T.C. 91 (20...
Tuesday, August 7, 2018

Ninth Circuit Withdraws Altera Opinions (8/7/18; 8/13/18)

›
The Ninth Circuit has withdrawn its opinions in Altera Corp. et al. v. Commissioner , ___ F.3d ___, 2018 WL 3542989, 2018 U.S. App. LEXIS 2...
Wednesday, July 25, 2018

Developments - Federal Tax Procedure Book 2018 Editions and Altera (7/25/18; 7/27/18)

›
The 2018 editions of the Tax Procedure Book (Student Edition and Practitioner Edition) are available for download on SSRN as of 7/17/18.  Th...
Monday, November 26, 2012

Arbitration to Settle Cross-Border Transfer Pricing Disputes between Competent Authorities Under Tax Treaties (11/26/12)

›
Reuters reports that the United States is having apparent success in using "baseball arbitration" to settle disputes under the mut...