Alston & Bird Tax Blog

International Tax ADVISORY: Big Tax Court Win for Eaton in Canceled APA Case

By and

The IRS abused its discretion when it canceled two advance pricing agreements. Our International Tax Group covers Eaton’s victory in the Tax Court and how it allays concerns about how worthwhile an APA can be.

  • Public and judicial scrutiny
  • Standard of review
  • Where do we go from here?

Read the full advisory here.

About Henry Birnkrant

Henry Birnkrant focuses his practice on transfer pricing matters and U.S. federal income taxation of domestic and cross-border business transactions.

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About Stefanie Kavanagh

Stefanie Kavanagh is an associate in the Federal & International Tax Group. She focuses her practice on tax planning and structuring for domestic and international business entities as well as matters relating to real estate investment trusts.

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