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US: Amazon wins tax dispute over cross-border IP transfer, but favorable tax treatment may no longer be available

Earlier this year in Amazon v. Commissioner, 148 T.C. No. 8 (March 23, 2017), the U.S. Tax Court issued a 207-page decision largely upholding Amazon’s tax treatment of an intellectual property transfer in 2005 and 2006 from...more

US: Proposed "Border Adjustment Tax” could kill foreign IP holding companies

With President Trump in the White House and a Republican majority in both the House and Senate, tax reform is once again high on the agenda. Several weeks ago, President Trump promised “a tax reform bill that will reduce our...more

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