US Tax Court and IRS at odds over transfer pricing in Veritas

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cookies Settings

US Tax Court and IRS at odds over transfer pricing in Veritas

November 24 2010
irsbadge50.png

The IRS’ Action on Decision (AOD), on November 10 2010, stating it does not agree with the result or reasoning of the US Tax Court’s decision in Veritas Software Corp. v. Commissioner, brought a spectrum of transfer pricing conflicts to light as the US Tax Court and IRS struggle to find common ground.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

NewsUnited StatesTransfer Pricing
more across site & shared bottom lb ros

More from across our site

Direct Tax
EU flag large
This week in tax: EU nations drop US pillar two carve-out objections
The climbdowns pave the way for a side-by-side deal to be concluded this week, as per the US Treasury secretary’s expectation; in other news, Taft added a 10-partner tax team
Sam Sholli, December 19 2025
Direct Tax
Merger international
Hogan Lovells, Cadwalader to merge in ‘largest combination in history’
A vote to be held in 2026 could create Hogan Lovells Cadwalader, a $3.6bn giant with 3,100 lawyers across the Americas, EMEA and Asia Pacific
Noemi Distefano, December 18 2025
Direct Tax
Libya
Whose tax is it anyway – Libya’s permanent establishment conundrum
Foreign companies operating in Libya face source-based taxation even without a local presence. Multinationals must understand compliance obligations, withholding risks, and treaty relief to avoid costly surprises
Salaheddin El Busefi , December 18 2025
Indirect Tax
uksc-court-sittings-2023.jpg
HMRC scores Supreme Court VAT victory over Hotel La Tour
Hotel La Tour had argued that VAT should be recoverable as a result of proceeds being used for a taxable business activity
Sam Sholli, December 17 2025
Direct Tax
Luis coronado
EY recruits provided AI training but still taught ‘old way’
Tax professionals are still going to be needed, but AI will make it easier than starting from zero, EY’s global tax disputes leader Luis Coronado tells ITR
Sam Sholli, December 17 2025
Direct Tax
kpmg.jpg
KPMG reports 7.5% tax and legal services revenue increase
AI and assisting clients with navigating global tax reform contributed to the uptick in turnover, the firm said
Sam Sholli, December 16 2025
Direct Tax
scott bessent.jpg
US Treasury secretary eyes pillar two deal finalisation this week
In a post on X, Scott Bessent urged dissenting countries to the US/OECD side-by-side arrangement to ‘join the consensus’ to get a deal over the line
Tom Baker, December 16 2025
Direct Tax
Business deal mergers and acquisitions
Winston & Strawn and Taylor Wessing merger confirmed, new brand unveiled
A new transatlantic firm under the name of Winston Taylor is expected to go live in May 2026 with more than 1,400 lawyers and 20 offices
Noemi Distefano, December 15 2025
Direct Tax
Copy of What Corporates Want 2025.png
Italy’s opaque tax system underlies in-house discontent, advisers say
As ITR’s exclusive data uncovers in-house dissatisfaction with case management, advisers cite Italy’s arcane tax rules
Tom Baker, December 15 2025
Direct Tax
Horse racing
A taxing week: HMRC’s GfC13 puts tax advisers in an unwinnable situation
The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
Tom Baker, December 12 2025
Gift this article