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Different Viewpoint Not a Misrepresentation: Tax Court Holds IRS Abused Its Discretion in Cancelling Eaton’s APAs

USA - August 30 2017 On July 26, 2017, the Tax Court ruled that the IRS abused its discretion when it retroactively cancelled two Advance Pricing Agreements (APAs) with…

J. Clark Armitage, Elizabeth J. Stevens

Different Viewpoint Not a Misrepresentation: Tax Court Holds IRS Abused Its Discretion in Cancelling Eaton’s APAs

USA - August 24 2017 On July 26, 2017, the Tax Court ruled that the IRS abused its discretion when it retroactively cancelled two Advance Pricing Agreements (APAs) with…

J. Clark Armitage, Elizabeth J. Stevens

Is It the Real Thing? The IRS Makes $9+ Billion of Transfer Pricing Adjustments Against The Coca-Cola Company

USA - December 23 2015 On September 17, 2015, the IRS issued a statutory notice of deficiency to the Coca-Cola Company, increasing its federal income taxes for 2007-2009 by…

J. Clark Armitage, Natalie Punchak

The final OECD BEPS tome has arrived

Global, OECD - October 8 2015 Remarkably on schedule, the OECD this week issued a comprehensive and integrated set of measures to attack base erosion and profit shifting (BEPS) on…

J. Clark Armitage, Peter A. Barnes, Kirsten Burmester, Neal M. Kochman, H. David Rosenbloom

Trategic resets under the new MAP and APA revenue procedures

USA - September 23 2015 The IRS recently replaced Rev. Proc. 2006-54 for requesting assistance under the Mutual Agreement Procedure ("MAP") article of U.S. tax treaties, and…

J. Clark Armitage, Neal M. Kochman, Sae Jin Yoon