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- Title
Transfer Pricing.
- Authors
Oates, Mark A.; O'Brien, James M.
- Abstract
The article reports on the decision of the U.S. Internal Revenue Service (IRS) not to appeal to VERITAS Software Corp. (VERITAS) despite its opposition to the Tax Court's factual findings and legal reasoning. It discusses the implications of the VERITAS case that involved requirement related to cost sharing agreements. It notes that IRS released its Action on Decision (AOD) in the VERITAS case on November 10, 2010 which shows that it disagrees with the court's decision.
- Subjects
UNITED States; TAX court decisions; UNITED States. Internal Revenue Service; VERITAS Software Corp.; UNITED States. Tax Court; COST shifting; ACTIONS &; defenses (Law)
- Publication
International Tax Journal, 2011, Vol 37, Issue 1, p9
- ISSN
0097-7314
- Publication type
Article