Amanda Leon Explores Transfer Pricing Litigation on ABA Virtual 2020 May Tax Meeting

Transfer pricing cases continue to crowd the courts and increasingly produce decisions with ramifications well beyond transfer pricing... and even tax. This panel will analyze and debate the procedural, substantive, and policy dimensions of recent transfer pricing decisions and pending cases. Our panelists will explore the intersection of tax law, administrative law, and litigation procedure in cases such as Altera, Amazon, Facebook, and 3M, critically examining the taxpayer’s and the government’s positions and identifying their strengths, weaknesses, and broader implications.