Skip to Main Content
 

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

July 21, 2017, 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.”

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.

________________________________________________

About Caplin & Drysdale
Having celebrated our 50th Anniversary in 2014, Caplin & Drysdale continues to be a leading provider of legal services to corporations, individuals, and nonprofits throughout the United States and around the world. We are also privileged to serve as legal advisors to accounting firms, financial institutions, law firms, and other professional services organizations.

The firm's reputation over the years has earned us the trust and respect of clients, industry peers, and government agencies. Moreover, clients rely on our broad knowledge of the law and our keen insights into their business concerns and personal interests. Our lawyers' strong tactical and problem-solving skills -- combined with substantial experience handling a variety of complex, high stakes, matters in a boutique environment -- make us one the nation's most distinctive law firms.

With offices in New York City and Washington, D.C., Caplin & Drysdale's core practice areas include:
For more information, please visit us at www.caplindrysdale.com.
Washington, DC Office:
One Thomas Circle NW
Suite 1100
Washington, DC 20005
202.862.5000
New York, NY Office:
600 Lexington Avenue
21st Floor
New York, NY 10022
212.379.6000

___________________________

Disclaimer
This communication does not provide legal advice, nor does it create an attorney-client relationship with you or any other reader. If you require legal guidance in any specific situation, you should engage a qualified lawyer for that purpose. Prior results do not guarantee a similar outcome.

Attorney Advertising
It is possible that under the laws, rules, or regulations of certain jurisdictions, this may be construed as an advertisement or solicitation.
© 2019 Caplin & Drysdale, Chartered
All Rights Reserved.

Related Professionals

Related Practice Area(s)