
The Veritas case, which came to an end in November 2010 after the Internal Revenue Service (IRS) decided that it would not appeal the decision of the Ninth Circuit Court of Appeals in the case, covered the value of the transfer of marketing and technical intangibles in a cost-sharing agreement between Veritas, a software company, and its Irish subsidiary. The tax authorities argued that the cost of the transaction should have been $1.5 billion more than was paid.
Symantec, which subsequently bought Veritas, won the North America In-house Tax Team of the Year award at the Americas Tax Awards, which were presented last night in New York. In Latin America, the equivalent
Other big winners included PwC, which was named the Latin America Tax Firm of the Year, and Cleary Gottlieb Steen & Hamilton, which won the same award for North America. Deloitte was
Awards were presented to the best firms for tax and transfer pricing in eight South American jurisdictions, Canada, Mexico, Puerto Rico and six US cities. An award for the best tax disputes firm of the year was also presented in each of these locations, except for the US.
Each of these categories was also included in the North and South America regional awards, which also comprised awards for industry sectors: banking, energy, media & entertainment and private equity, specialist awards for areas such as capital markets and M&A tax.
The only individual winner was John DiCicco, head of the Tax Division at the US Department of Justice, though he was unable to attend the ceremony at the Waldorf-Astoria hotel.
Private-practice firms were invited to enter for the awards by submitting examples of their best work between June 2010 and June 2011. These entries were assessed by the editorial staff of International Tax Review, which included speaking to practitioners and tax directors. Shortlists were published in August and these were reviewed to arrive at the set of winners.
Read the list of winners here.
Find out who was nominated here.