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- Title
Recent Transfer Pricing Cases.
- Authors
YODER, LOWELL D.
- Abstract
The article discusses various transfer pricing cases dealing with issues considered by the U.S Internal Revenue Service such as the identification of compensable intangibles that were transferred by U.S. corporations to foreign subsidiaries and the pricing of those intangibles. It discusses the case of Amazon.com Inc. that entered into a costsharing arrangement and the case of Veritas Software Corp., in which the Tax Court rejected the use of the income method of valuation by the IRS.
- Subjects
TRANSFER pricing; UNITED States. Internal Revenue Service; VALUATION of intangible property; FOREIGN subsidiaries; AMAZON.COM Inc.; COST shifting; VERITAS Software Corp.; TAX court decisions
- Publication
International Tax Journal, 2014, Vol 40, Issue 5, p3
- ISSN
0097-7314
- Publication type
Article