Amazon.com, Inc. v. Commissioner (I)

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March 23, 2017

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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 (I)
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.
Amazon.com, Inc. v. Commissioner
PDF, Size: 634 KB

See Also

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

Court Case Digests
March 23, 2017

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.