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

Aug 04,2017

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 (for 2001-05 tax years) & APA II (for 2006-10 tax years) with taxpayer & its subsidiaries establishing a transfer pricing methodology for its international transactions but were cancelled by IRS in 2011 on the basis that taxpayer had not complied with appl...


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