U.S. Tax Court Sustains IRS's Transfer Pricing Reallocations Under Comparable Profits Method
On 18 November 2020, an opinion of the U.S. Tax Court was published concerning whether the IRS abused its discretion by making transfer pricing reallocations of royalties by employing a comparable profits method (CMP).
For the years concerned (2007-2009), the Coca-Cola Co. and its domestic subsidiaries ("Coca-Cola") joined in filing consolidated Federal income tax returns. Coca-Cola's foreign…
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