The Resource Can a cost-sharing arrangement prevent a tax shelter label?

Can a cost-sharing arrangement prevent a tax shelter label?

Label
Can a cost-sharing arrangement prevent a tax shelter label?
Title
Can a cost-sharing arrangement prevent a tax shelter label?
Creator
Subject
Language
eng
Summary
This article discusses Microsoft and the term "tax shelter". Microsoft Corp. and the U.S. government have been involved in a tussle over various matters in connection with the government's desire to examine transfer pricing concerns. On 12 October 2016 the government filed a response saying one of the transactions at issue is "unquestionably" a tax shelter for purposes of section 7525. The purpose of this article is not to perform any legal analysis of the term "tax shelter" as used in section 7525(b). Rather, it is to discuss facts not included in the three documents filed 27 and 28 October 2016. Perhaps those background facts will help disinterested observers better analyse the situation and provide guidance regarding other structures that achieve tax benefits
Citation source
In: Tax notes international. - Falls Church. - Vol. 84 (2016), no. 8 ; p. 779-782
http://library.link/vocab/creatorName
Kadet, J.M
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • cost sharing arrangement
  • tax shelter
  • transfer pricing
Label
Can a cost-sharing arrangement prevent a tax shelter label?
Instantiates
Publication
Label
Can a cost-sharing arrangement prevent a tax shelter label?
Publication

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