Bloomberg BNA Quotes Patricia Lewis: Safe Harbors for Cost Sharing a Lesson from Amazon

Bloomberg BNA

Treating cost-sharing as a safe harbor might have significantly reduced the amount of U.S. transfer pricing litigation, tax practitioners told an IRS official during a panel discussion of the Amazon U.S. Tax Court case.

“If the cost-sharing regulations had been expressed as a safe harbor, it would be a very different world from a litigation perspective,” Patricia Lewis, a member of Caplin & Drysdale, said July 20 at the National Association for Business Economics’ transfer pricing conference. “The struggle to contain the cost-sharing regulations within the arm's-length rubric has been a challenge.”

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Excerpt taken from the article “Safe Harbors for Cost Sharing a Lesson From Amazon: Practitioners” by Sony Kassam for Bloomberg BNA.


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