The Resource Amazon moves toward trial in high-profile case challenging IRS income method for valuing intangibles

Amazon moves toward trial in high-profile case challenging IRS income method for valuing intangibles

Label
Amazon moves toward trial in high-profile case challenging IRS income method for valuing intangibles
Title
Amazon moves toward trial in high-profile case challenging IRS income method for valuing intangibles
Creator
Subject
Language
eng
Summary
Amazon.com Inc.'s transfer pricing dispute with the Internal Revenue Service goes to trial 3 November 2014 in Seattle. A central issue in the case is the valuation of intangibles under a cost sharing arrangement between the U.S. company and its European subsidiary. Amazon takes the position that the discounted cash flow method used by the IRS was invalidated by the U.S. Tax Court in Veritas Software Corp. v. Comr. In this article, practitioners discuss the dispute over valuation and the agency's prospects for arriving at a more favourable ruling under different facts
Citation source
In: Tax management transfer pricing report. - Arlington. - Vol. 23 (2014),
http://library.link/vocab/creatorName
Gregory, D.W
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • intangibles
  • cost sharing arrangement
  • valuation
  • case law
Label
Amazon moves toward trial in high-profile case challenging IRS income method for valuing intangibles
Instantiates
Publication
Label
Amazon moves toward trial in high-profile case challenging IRS income method for valuing intangibles
Publication

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