Law360 (Jan. 3, 2021, 2:23 p.m. EST) – The courts will be looking at closely watched international tax cases this year, including disputes over the Internal Revenue Service’s transfer pricing practices and the valuation of intangible real estate the agency has used to reallocate billions of dollars from overseas subsidiaries of US companies.
The IRS made some notable gains in transfer pricing cases last year, including when the U.S. Treasury Court ruled Coca-Cola in a long-running $ 3.3 billion dispute, but litigation in this area is far from over. As the New Year progresses, the Finance Court will hear Facebook and other large multinational corporations challenge their tax charges in cases that collectively …
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