Can one rely on APA in US? Eation Corp is challenging the Internal Revenue Service in U.S. Tax Court

Eation Corp is challenging the Internal Revenue Service in U.S. Tax Court, arguing that the agency broke agreements dealing with how the company moves assets and money across international borders.

Eaton is contesting a $75 million tax bill that the IRS imposed on the company in a case that could have broad impact on other companies’ “transfer pricing” practices, the industry term for shifting assets across borders to reduce taxes.

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