Tag: License of technology

US vs. Sundstrand Corp, Feb. 1991, United States Tax Court

US vs. Sundstrand Corp, Feb. 1991, United States Tax Court

Sunstrand licenced technology to its Singapore-based subsidiary, SunPac. The United States Tax Court ruled that the amounts paid by Sunstrand to SunPac did not constitute and arm’s-length consideration under Section 482, but also that the IRS overstepped its authority in calculating taxable net income. The Court also eliminated interest penalties imposed by the IRS. US-Sundstrand_decision_02191991 ... Continue to full case