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Taxation & Estate Planning

: TaxProf Blog

IRS Loses Billion Dollar Transfer Pricing Case

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The IRS lost a billion dollar § 482 transfer pricing case yesterday. Veritas Software Corp. v. Commissioner, 133 T.C. No. 14 (Dec. 10, 2009): P entered into a cost-sharing arrangement with S, its foreign subsidiary, to develop and manufacture storage management software products. Pursuant to the cost-sharing arrangement, P granted...

Full post as published by TaxProf Blog on December 11, 2009 (boomark / email).

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