Bloomberg BNA Quotes Patricia Lewis: Safe Harbors for Cost Sharing a Lesson from Amazon
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.”
To view the full article, please visit Bloomberg BNA's website (subscription required).
Excerpt taken from the article “Safe Harbors for Cost Sharing a Lesson From Amazon: Practitioners” by Sony Kassam for Bloomberg BNA.
- Senior Counsel