January 01, 2024
The U.S. Supreme Court’s upcoming decision on a constitutional challenge to a repatriation provision could reverberate beyond the tax code’s measures for deferred foreign income, while Coca-Cola may make its own constitutional arguments in a long-running $3.3 billion transfer pricing dispute. Here, Law360 looks at key international tax cases to follow during 2024.
December 15, 2023
The U.S. asked the Eighth Circuit on Friday to reject a transfer pricing method used by the U.S. Tax Court in a decision finding medical device company Medtronic Inc. underreported its income, saying the methodology violated Treasury regulations and still failed to accurately account for the company's income.