The U.S. Tax Court denied Amazon’s motion for a partial summary judgment related to a cost-sharing arrangement (CSA) under the transfer pricing provisions of the U.S. Internal Revenue Code. In Amazon.com, Inc. & Subsidiaries v. Commissioner of Internal Revenue, the court, finding a genuine dispute of material fact, held that Amazon must establish that costs are mixed before applying an allocation method to them.
U.S. Tax Court Denies Amazon Summary Judgment in Transfer Pricing Case
Posted by celliott on Sep 22, 2014 11:30:54 AM
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Topics: Amazon, Amazon.com Inc. & Subsidiaries v. Commissioner, International Tax, Tax, U.S. Tax Court, Uncategorized