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Amazon Savors a Huge Win Against IRS on Transfer Pricing

There has been a substantial development in the past week affecting international business as Amazon savors a huge win against the IRS on transfer pricing related tax disputes.  The findings of a US Tax Court were stark: "The IRS acted in an arbitrary, capricious, and unreasonable manner when it applied...

Medtronic Beats IRS in Complex Tax Matter Involving Transfer Pricing

Medtronic PLC, a medical device manufacturer who used to have operations in Puerto Rico, has defeated the IRS in US Tax Court, resolving a $1.4 billion dispute.  The key issue in the case centered on transfer pricing - transactions between different divisions or companies owned by the same corporation or...

Employers Must Withhold Payroll Taxes on Employment Related Judgments

By Janathan L. Allen, APC of Janathan L. Allen, APC posted in California Tax on Friday, October 16, 2015. The California Court of Appeal recently provided clarification and confirmation of a corporation's responsibility to withhold payroll taxes on employment related settlements or judgments.  When an employee reaches a settlement or...