David Rosenbloom Speaks to Tax Notes on Cost Sharing

07.22.2020
Tax Notes

Although the U.S. Supreme Court’s refusal to review Altera v. Commissioner ended one attack on Treasury’s cost-sharing regulations, challenges to their validity will likely remain a fixture of transfer pricing litigation for the foreseeable future. 

. . .

This history has led some to question the wisdom of the cost-sharing regulatory scheme and the government’s ability to defend it in court. “Cost sharing was probably the dumbest thing [the] IRS ever did and the worst job of defense it ever mustered,” said David Rosenbloom of Caplin & Drysdale

For the full article, please visit Tax Notes’ website (subscription required).

Attorneys

Related Practices/Industries

Jump to Page

We use cookies to make your experience of our website better. By continuing to browse this site you content to the use of cookies. Please visit our Privacy Policy for more information.