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Part 7 of 7 Tax Audits and Litigation Tax Series: Perspectives on Amazon.com, Inc. v. Commissioner

**This is a previously recorded program, originally recorded on May 18, 2017.
The stakes could hardly have been higher for the IRS in its $1.5 billion transfer pricing loss to Amazon on March 23. The Tax Court’s opinion has many lessons and implications for multinationals’ transfer pricing, and for the IRS and taxpayers in transfer pricing disputes.
Our panel brings together an international tax lawyer, an economist, and a tax litigator to discuss key takeaways. Topics will include the factors leading to Amazon’s win, where the decision leaves the IRS in disputes under its 1995 and 2005 cost sharing regulations, and the implications for multinationals when selecting and applying transfer pricing methods.
This program was sponsored by the International Tax Committee and the Tax Audits and Litigation Committee of the D.C. Bar Taxation Community.
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