US: The Mayo decision and the arm’s-length standard
Kenneth Clark and Ronald Schrotenboer of Fenwick & West explain that although the Supreme Court’s decision in Mayo may lead the IRS to argue that it has significant discretion, taxpayers still have a number of tools left to defend the traditional definition of the arm’s-length standard.
Unlock this article.
The content you are trying to view is exclusive to our subscribers.
To unlock this article: