Law360 Quotes Mark Allison on Transfer Pricing Cases After Amazon Loss
The Internal Revenue Service's blistering loss in a $1.5 billion transfer pricing dispute with Amazon has experts calling for a re-examination of the agency's valuation methodologies in order to prevent it from wasting its own resources and those of taxpayers.
Mark Allison of Caplin & Drysdale, Chartered said the IRS isn’t necessarily being irresponsible by scrutinizing and litigating transfer pricing issues, since these cases tend to be very fact-driven with the circumstances of each one needing to be considered individually, and the agency has a mandated responsibility to protect its tax base.
“The IRS quite understands that there are transfer pricing strategies that are out there that are designed to move this kind of value offshore, and the IRS has every economic incentive to change those dollars,” Allison said.
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Excerpt taken from the article “IRS Must Rethink Transfer Pricing Cases After Amazon Loss” by Vidya Kauri for Law360.
- Senior Counsel