Analysis

Microsoft Ruling Highlights Need To Document Biz Decisions

Law360 (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...

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