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Reg. § 1.482-1(a)(3): Has the Ship Sailed with Intersport?


Intersport Fashions West Inc. v. United States.2. In this article, we pay particular attention to each of the different parts of Reg. § 1.482-1(a)(3), ensuring that each  ...

Intersport and Taxpayer-Initiated Transfer Pricing ... - DLA Piper


May 17, 2012 ... In Intersport Fashions West Inc. v. U.S., 109 A.F.T.R.. 2d 2012-927 (Fed. Cl. 2012) , the U.S. Court of Fed- eral Claims held that a U.S. taxpayer ...

Dynetics, Inc. v. United States - United States Court of Federal Claims


May 31, 2015 ... the United States Air Force Research Laboratory, pursuant to which it was .... 28 U.S.C. § 1346(a)(1); see also Intersport Fashions West, Inc. v.

Voluntary Transfer Pricing Adjustments and Voluntary Payments of Tax


Aug 23, 2013 ... US transfer pricing rules: An overview ... sider the basics of the US transfer pricing system, as an ..... 2013, Intersport Fashions West, Inc. v.

Ivins, P h il l ip s Bar k e r U.S. Transfer Pricing Developments

www.ipbtax.com/media/news/263_IPB Promo - 2013 US TP Update _BNA NY Dec 2013_ _JBD_ W.pdf

Dec 5, 2013 ... Intersport Fashions West ... that U.S. taxpayers should talk to the IRS before completing APA filings with the Indian ..... Amazon.com Inc. v.

Ivins, Phillips Bark er U.S. Transfer Pricing Developments

www.ipbtax.com/media/news/296_05_22_14 DC Bar 2014 - TP Update V2 IPB Web Site.pdf

May 22, 2014 ... Intersport Fashions West. ▫ BMC Software. ▫ Amazon. ... Notably, double the number of US-initiated double tax cases ..... Amazon.com Inc. v.

Fairchild Corporation to Buy Intersport Fashions West and Hein ...


Feb 24, 2009 ... Fairchild Corporation, best known as an aircraft firm, will purchase IFW, one of the largest U.S. motorcycle apparel companies.

Internal Revenue Manual - 4.10.13 Certain Technical Issues (Cont. 1)


See Intersport Fashion West, Inc. v. United States, 103 Fed. Cl. 396 (2012). However, taxpayers may claim a setoff against the Service's IRC 482 allocation for ...

Taxpayers Affirmative Use of IRC 482 - IRS.gov


Mar 24, 2016 ... On a timely filed U.S. income tax return, the taxpayer is reporting the results .... Intersport Fashions West v. .... Tax'n Inc., Est and Gift Chapter 79:.

US transfer pricing developments | International Tax Review


Jun 12, 2013 ... (See Medtronics, Inc v Commissioner, TC Dkt No. ... In Intersport Fashions West v U.S. ___ Ct Cl. ___ (2012), the Court of Federal Claims ruled ...