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LimeGreenIP News

Tag Archives: IRS

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

U.S. – Considering the value of manufacturing trade secrets

These days, licensing between affiliate members of a multinational corporate family is prevalent. While reaching agreement between friendly parties on licensing terms may be easier than it normally would be between arms-length parties from an economic perspective, these transactions are likely to come under intense scrutiny from the relevant tax authorities worldwide. Understanding the value