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

November 24 2010

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

more across site & shared bottom lb ros

More from across our site

Indirect Tax

IBS vs. ICMS: why Brazil’s new VAT is a fundamental paradigm shift

While the IBS incorporates taxable events previously covered by state and municipal taxes, its governance and operational logic represent a significant departure from the legacy model

Wesley Fragas, March 31 2026

Direct Tax

Exclusive: Ryan continues London investment with new UK HQ

The new office on the fourth floor of 4 More London will span 14,230 square feet, with the potential to expand to the first and second floors

Tom Baker, March 30 2026

Direct Tax

Implementing the OECD side-by-side package: what MNEs must do now

MNEs now face a shift from modelling to execution as the side‑by‑side deal forces tax teams to upgrade systems, harmonise data, and prevent costly pillar two mismatches

Jelena Mihić Munjić, March 30 2026

Direct Tax

A taxing week: Big four should clarify their AI strategies, or risk further talent losses

As recent surveys suggest a disconnect between AI adoption and employee engagement, the big four risk digging themselves into a strategic hole

Sam Sholli, March 27 2026

Direct Tax

This week in tax: Survey shows widespread use of AI in tax, but strategy lacking

Almost three-quarters of surveyed tax professionals are concerned about inaccurate AI outputs; in other news, Dentons hired a partner from CMS to lead its Belgian tax team

Sam Sholli, March 27 2026

Transfer Pricing

AI will power HMRC’s continued quest for TP revenue, advisers suggest

Long-running, high-value and complex enquiries are a significant reason for HM Revenue and Customs’s increased TP yield, experts suggest

Sam Sholli, March 26 2026

Direct Tax

What Corporates Want India technical knowledge header

Clients laud Indian tax advisers’ technical knowledge amid legislative upheaval

Landmark legal updates in India have led companies to prioritise specialised tax advisers over accountants, ITR has found

Tom Baker, March 26 2026

Indirect Tax

Brazil’s tax reform: how the IBS impacts municipalities

Brazil’s shift to a nationwide consumption tax is more than conceptual; it fundamentally transforms municipal revenue, enforcement, and administrative disputes

Wesley Fragas, March 25 2026

Indirect Tax