Law360 (January 1, 2020, 12:04 PM EST) -- The key cross-border tax cases that specialists are tracking this year include high-stakes disputes over the U.S. Treasury Department's rulemaking authority and questions about whether multinationals can continually rely on the IRS' long-term approval of their transfer pricing methods.
On the surface, each case involves a major American multinational that has accused the Internal Revenue Service of abusing its discretion in reallocating income from foreign affiliates. Beyond tax disputes, the cases collectively touch on broader issues involving administrative law, the role a foreign unit's risk plays in transfer pricing and the IRS' alleged about-face after years of agreeing to a multinational's...
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