Microsoft Ruling Highlights Need To Document Biz Decisions

By Natalie Olivo (January 30, 2020, 9:37 PM EST) -- A Washington federal judge recently took a broad interpretation of what constitutes a tax shelter when ordering Microsoft to turn over documents to the Internal Revenue Service — a decision that companies shouldn't ignore during their own correspondence with practitioners.

A federal judge's decision in an IRS dispute with Microsoft may signal a potential shift in U.S. courts toward viewing tax-motivated business decisions as tax avoidance. (AP) U.S. District Judge Ricardo S. Martinez ordered Microsoft Corp. this month to hand over 174 documents at the center of an audit regarding the tech giant's cost-sharing arrangements with its Puerto Rican subsidiary to develop...

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!


Hello! I'm Law360's automated support bot.

How can I help you today?

For example, you can type:
  • I forgot my password
  • I took a free trial but didn't get a verification email
  • How do I sign up for a newsletter?
Ask a question!