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...
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