International Rulings

US Tax Court : Accepts Columbia Sportswear's TP- study, rejects Department's attempt to recalculate tax base

Indiana (US) Tax Court grants summary judgment in Columbia Sportswear USA Corporation’s (assessee) favour in respect of its purchase of sporting / hiking products from AE for tax years 2005-2007,

Feb 03, 2016

Australian Federal Court upholds inter-company interest on $ 2.5 billion loan as 'excessive'

Australian Federal Court rules against Chevron (an American multinational energy corporation) in multi-million dollars transfer pricing case on inter-company funding, holds interest paid by Chevron Australia to a US affiliate

Nov 02, 2015

US Tax Court invalidates IRS Cost-Sharing Regulations providing for sharing stock-based compensation costs

US Tax Court invalidates part of IRS Cost-Sharing Regulations, 2003 (Final Rule) which provides that taxpayers have to share stock-based compensation costs under cost sharing agreement with AE for services

Aug 03, 2015

US Court: Allows one-time deduction of repatriated cash-dividend, holds backdated receivables not related-party “indebtedness”

US Court reverses disallowance of repatriated cash-dividends to US corporations by taking cognisance of the one-time deduction; Commissioner had disallowed repatriated dividend-deduction based on subsequent year's Closing Agreement which showed

Mar 23, 2015

US Tax Court: Upholds CUP for discounted purchase from subsidiary characterized as licensee, not subcontractor

Sundstrand Corporation and Subsidiaries V. Commissioner of Internal Revenue (96 T.C. 226)

Apr 17, 2013

US Tax Court : Upholds CUP, despite higher profits to Asian entity due to lower costs

Compaq Computer Corporation & Subsidiaries v Commissioner of Internal Revenue 113 T.C. No. 17

Mar 04, 2013