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