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

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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.