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Tag Archives: IP transfer

US: Amazon wins tax dispute over cross-border IP transfer, but favorable tax treatment may no longer be available

Earlier this year in Amazon v. Commissioner, 148 T.C. No. 8 (March 23, 2017), the U.S. Tax Court issued a 207-page decision largely upholding Amazon’s tax treatment of an intellectual property transfer in 2005 and 2006 from the U.S. to a related European corporation. Contesting Amazon’s valuation of the transferred intangibles, the Internal Revenue Service