CUT Method Prevails in Amazon’s Transfer Pricing War With IRS

BVLaw
Court Case Digests
March 23, 2017
5961 Catalog and Mail-Order Houses
454110 Electronic Shopping and Mail-Order Houses
federal taxation
transfer pricing, beta, discount rate, expert testimony, intangible assets, discounted cash flow (DCF), deficiency, arm's length, income tax, comparable uncontrolled transaction

Amazon.com, Inc. v. Commissioner
2017 U.S. Tax Ct. LEXIS 9
US
Federal Court
Federal
United States Tax Court
Robert Reilly, John Willis (petitioner [Amazon], valuation); Daniel Frisch, David Haigh, Harlow Higinbotham (respondent [IRS], valuation)
Lauber

Summary

In transfer pricing case, Tax Court says Amazon more accurately determined buy-in and cost-sharing payments by using CUT method to value separately three types of intangible assets; IRS’s DCF analysis results in improper enterprise valuation, court says.

See Also

Amazon.com, Inc. v. Commissioner

In transfer pricing case, Tax Court says Amazon more accurately determined buy-in and cost-sharing payments by using CUT method to value separately three types of intangible assets; IRS’s DCF analysis results in improper enterprise valuation, court says.

CUT Method Prevails in Amazon’s Transfer Pricing War With IRS

: In transfer pricing case, Tax Court says Amazon more accurately determined buy-in and cost-sharing payments by using CUT method to value separately three types of intangible assets; IRS’s DCF analysis results in improper enterprise valuation, court says ...