Alston & Bird Tax Blog

International Tax ADVISORY: Tax Court Déjà Vu – IRS Tried, and Failed, to Overturn Veritas

By and

Unsurprisingly, the IRS got the same result by trying the same thing. Our International Tax Group analyzes the agency’s latest effort to use a discounted cash flow analysis to audit a cost-sharing agreement.

  • The difference between #255 million and $3.6 billion
  • Using the comparable uncontrolled transaction method
  • Applying the 2011 cost-sharing regulations

Read the full advisory by clicking 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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