9th Circuit Reverses Tax Court Decision IRS Wins Big (They should have hired SELIG)

As the Ninth Circuit noted, transactions between related parties can provide opportunities for minimizing or avoiding taxes, particularly when a foreign subsidiary is located in a low-tax jurisdiction. United States companies can shift profits that would be subject to tax in America offshore to avoid tax. Similarly, related companies can identify and shift costs between American and foreign jurisdictions to minimize tax exposure. Section 482 was passed to address the risk of multinational corporation tax avoidance. Regulations promulgated by the Treasury under section 482 authorize the IRS to allocate income and costs among related entities, and 26 C.F.R. section 1.482-7A(d)(2), which was at issue in this decision, was promulgated under section 482.

Excerpt from Roger Russell’s Accounting Today article dated 24 July 2018

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