NYU Professors Urge 9th Circ. To Uphold Amazon Tax Win
Law360 (July 9, 2018, 6:33 PM EDT) -- Two law professors have urged the Ninth Circuit to uphold a U.S. Tax Court decision in favor of Amazon.com Inc. in a transfer pricing dispute with the Internal Revenue Service, saying the agency was relying on an incorrect reading of cost-sharing regulations.
The IRS' interpretation that residual business assets such as goodwill and going concern value be compensated under cost-sharing agreements did not apply in 2005 when Amazon made an agreement that granted its European affiliate certain asset rights, the professors at the New York University School of Law said in an amicus brief filed Friday. Instead, the professors said, the...
Stay ahead of the curve
In the legal profession, information is the key to success. You have to know what’s happening with clients, competitors, practice areas, and industries. Law360 provides the intelligence you need to remain an expert and beat the competition.
Access to case data within articles (numbers, filings, courts, nature of suit, and more.)
Access to attached documents such as briefs, petitions, complaints, decisions, motions, etc.
Create custom alerts for specific article and case topics and so much more!