Tag: Limits on IRS authority

US vs. Bankers Trust. September 2000

US vs. Bankers Trust. September 2000

This decision did not deal directly with transfer pricing, but it describes the limits on IRS authority to regulate beyond statuatory powers. US-BankersTrust_Decision_09202000 ... Continue to full case
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