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
Rules Surrounding IRA Rollovers Become Less Friendly to Taxpayers
Posted by celliott on Jun 26, 2014 8:44:31 AM
Earlier this year, the U.S. Tax Court made a controversial ruling regarding IRA rollovers that contradicted an IRS publication designed to explain the law to taxpayers. In Bobrow v. Commissioner, the court ruled that the one-rollover-per-year rule applies to all of a taxpayer’s IRAs in aggregate, rather than on an account-by-account basis.
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Topics: Bobrow v. Commissioner, IRA Accounts, IRA Rollovers, Tax, U.S. Tax Court, Uncategorized