Briefing on the Recent Tax Court's Decision in Veritas v. Commissioner and the Immediate Impact on Taxpayers

Morgan Lewis's Bart Bassett, Bill Colgin, and Neal Gordon will present this seminar, which will discuss the important points of the court's decision, its broad application to transfer pricing disputes in general, and various practical tips for taxpayers and advisors.

On December 10, the Tax Court released its decision in Veritas Software Corp. v. Commissioner, which addresses a number of current "hot button" transfer pricing issues. The decision will have an immediate impact on taxpayers and the IRS alike and provides a number of valuable lessons for taxpayers in terms of preparing and defending transfer pricing positions and documentation.

Topics to be discussed include:

• A review of the current cost-sharing environment, including common adjustments asserted by the IRS
• An analysis of the opinion and its treatment of the IRS's legal and economic theories
• Why the IRS's "akin to a sale" theory was rejected
• Why the taxpayer's CUT was adjusted
• The decision's significant impact on existing and future disputes
• Implications beyond cost sharing: the court's views of the definition of "intangible property" for purposes of Code sections 482 and 367(d)
• Practical lessons to consider regarding the preparation of transfer pricing documentation and strategies for its defense under audit

For more information or to register, please use the above registration link.

CA MCLE Credit
This activity has been approved for Minimum Continuing Legal Education credit by the State Bar of California in the amount of 1.5 hours and Morgan, Lewis & Bockius llp, Provider No. 4730, certifies that this activity conforms to the standards for approved education activities prescribed by the rules and regulations of the State Bar of California governing minimum continuing legal education.