David Rosenbloom Speaks to Tax Notes on Cost Sharing
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.
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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.
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