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- Title
Transfer Pricing: Tax Court Rejects IRS CIP on Cost Sharing Buy-ins in VERITAS.
- Authors
Oates, Mark A.; O'Brien, James M.
- Abstract
The article reports on the U.S. Tax Court rejecting the U.S. Internal Revenue Service's (IRS) Coordinated Issue Paper on Cost Sharing Buy-in (CIP) in Veritas Software Corp. It discusses the position taken by the IRS and Veritas Software Corp. in the case. It reports on the effect of the case on the bilions of dollars of adjustments and penalties claimed by the IRS on the multinational taxpayers and on the future of CIP itself.
- Subjects
UNITED States; UNITED States. Tax Court; UNITED States. Internal Revenue Service; VERITAS Software Corp.; COST shifting; ACTIONS &; defenses (Law)
- Publication
International Tax Journal, 2010, Vol 36, Issue 1, p17
- ISSN
0097-7314
- Publication type
Article