Analysis

IRS Must Rethink Transfer Pricing Cases After Amazon Loss

Law360, New York (March 24, 2017, 10:20 PM EDT) -- The Internal Revenue Service's blistering loss in a $1.5 billion transfer pricing dispute with Amazon has experts calling for a re-examination of the agency's valuation methodologies in order to prevent it from wasting its own resources and those of taxpayers.

The IRS had disagreed with the amount of upfront and regular payments that Amazon.com Inc.'s subsidiary in Luxembourg paid to the Seattle-based retailer in exchange for the right to use certain intellectual property for online European operations.

Using methodologies the U.S. Tax Court had already knocked down in another transfer pricing lawsuit against Veritas Software Corp. in 2009, the IRS made...

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!

TRY LAW360 FREE FOR SEVEN DAYS

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?
Beta
Ask a question!