International Rulings

US Appeals Court reverses Tax Court's CUP-acceptance in Medtronics, holds findings on comparability inadequate

US Court of Appeals (Eighth Circuit) reverses Tax Court’s acceptance of Medtronic’s adoption of comparable uncontrolled transaction ("CUT") method (with certain adjustments) for benchmarking royalty received from Medtronic Puerto Rico (AE) for

Aug 21, 2018

Ninth Circuit withdraws Altera opinion validating IRS-Regulation providing for sharing stock-based compensation costs

The Ninth Circuit Of US Court of Appeals withdraws its opinion in case of Altera Corporation “to allow time for the reconstituted panel to confer on this appeal”;  Earlier, the Ninth Circuit had

Aug 08, 2018

US Appeals Court reverses Altera decision, upholds IRS regulation requiring stock-based compensation costs sharing

US Court of Appeals (Ninth Circuit) (majority decision) overturns US Tax Court’s invalidation of part of IRS Cost-Sharing Regulations, 2003 (Final Rule) which provides that taxpayers have to share stock-based

Jul 25, 2018

Mauritius Tribunal directs disclosure of ‘secret comparables’ information for Customs Valuation purpose

Mauritius Assessment Review Committee allows taxpayer’s appeal, holds that Revenue should provide unedited version of the 2 Bills of Entry [‘secret comparables’] used to uplift value of taxpayer’s imported washing

May 28, 2018

Canadian Federal Court rejects Revenue’s oral-interview request of company personnel during TP-audit

Federal Court of Canada (‘the Court’) rejects Minister of National Revenue’s (‘Minister’) application to compel Cameco Corporation (‘Cameco’) to produce approximately 25 of its personnel (including CEO/ CFO etc.) for oral

Aug 29, 2017

US Tax Court holds cancellation of APAs by IRS as abuse of discretion

US tax Court holds that cancellation of APAs (entered with Eaton Corporation and Subsidiaries, ‘taxpayer’) by IRS was an abuse of discretion; Notes that IRS had entered into APA I

Aug 04, 2017