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...

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