Transfer Pricing

By Kevin Pinner

Exxon is entitled to a $274 million tax refund for a deduction of interest expenses fully allocated to the company by its partnership with Qatar to extract natural gas, a Texas federal court said Friday in an order that indicated $182 million in penalties should be returned as well.

By Kevin Pinner

U.S. Tax Court wrongly upheld the IRS denying a whistleblower award for information about a taxpayer's transfer pricing despite the agency failing to follow its internal procedures, the individual told the D.C. appeals court.

By Zak Kostro

The IRS didn't abuse its discretion in denying a whistleblower's bid for an award for information regarding alleged underpayments by a large multinational corporation, the U.S. Tax Court ruled Thursday, upholding the agency's determination that it had already identified the key issues for its investigation.

By Natalie Olivo

The IRS urged the U.S. Tax Court to validate regulations that Facebook parent Meta is challenging in its fight against a nearly $16 billion tax bill, arguing that the social media giant is recycling arguments the Ninth Circuit already rejected.

By Kevin Pinner

A Michigan court errantly allowed pharmaceutical giant Perrigo to avoid taxes on $212 million in profits by assigning a lucrative contract to a shell company that played no economic role in fulfilling its terms, the government told the Sixth Circuit.

By Kevin Pinner

The Netherlands is looking at amending its policy on negotiating tax treaties so that it could offer all developing countries the ability to levy taxes on payments for all types of services even when the services aren't performed in the treaty partner's jurisdiction, according to a consultation.