The Ninth Circuit rules on the definition of an “intangible”

The Ninth Circuit rules on the definition of an “intangible”

Rebel Curd, Robin Hart, Haruka Abe
Transfer Pricing

On August 16, 2019, the US Court of Appeals for the Ninth Circuit affirmed a decision of the US Tax Court regarding the definition of an intangible and the valuation method of intangible assets in relation to a cost-sharing arrangement (CSA) entered into prior to the 2009 temporary cost sharing regulations.The decision relates to the recent Amazon.com Inc. v. Commissioner case.

This Insights explores the history around the case and the argument behind the Ninth Circuit's decision.

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