Transfer Pricing

By Molly Moses

An engineer who spent three decades working for Eaton in the U.S. told the Tax Court on Tuesday that the company's affiliates in Puerto Rico and the Dominican Republic gained little expertise from U.S.-based personnel regarding the manufacture of industrial control products.

By Natalie Olivo

Facebook parent Meta urged the U.S. Tax Court to scrap part of its $16 billion tax bill, arguing that a recent decision in a related case blocks the Internal Revenue Service from allocating income based on transactions with an Irish affiliate.

By Kevin Pinner

The Sixth Circuit on Tuesday approved Perrigo's voluntary dismissal of its challenge to a Michigan federal court's adjustments to its transfer pricing analysis in a dispute with the government over an intercompany assignment of a contract to supply a stomach acid medication.

By Molly Moses

A U.S. Tax Court judge who heard from an Eaton Corp. tax official about the power management company's transfer pricing method Monday expressed frustration with the process used to extract data for the method, at one point calling exhibits detailing that process "impenetrable."

By Natalie Olivo

The IRS asked the U.S. Tax Court to back the $58 million in accuracy-related penalties the agency assessed against Facebook parent Meta for what the agency saw as erroneously claiming foreign tax credits on Brazilian income, arguing the penalty determination was procedurally valid.

By Molly Moses

Managers from Eaton's factories in the Dominican Republic and Puerto Rico described in court Friday how products were tested for quality at those facilities, while IRS attorneys seeking to downplay the significance of the island operations questioned the officials about where the quality standards were developed.