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.
Drug pricing rules and tariffs reshape transfer pricing for IP
In the article “Drug Pricing Rules and Tariffs Reshape Transfer Pricing for IP,” published in Bloomberg Tax, CRA’s Transfer Pricing experts Robin Hart and ...