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U.S. Tax Court Opinion that Determination of Separate Taxable Income not needed for Group Transfer Pricing Adjustment

|Approved Changes|United States
United States

On 29 February 2016, an opinion of the U.S. Tax Court was published concerning whether the IRS must determine separate taxable income of controlled entities for transfer pricing adjustment purposes and whether related transactions may be aggregated. The case involves Guidant Corp., the U.S. parent of a group engaged in the development, manufacture and sale of medical devices.

For the years con…

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