Partner Thomas Linguanti and associate Drew Cummings co-authored a Bloomberg Law article examining the US Tax Court case Facebook, Inc. v. Commissioner and the practical takeaways for tax departments facing audits.
Thomas and Drew highlight the case’s key lessons, including the need to align foreign transfer pricing positions, anticipate how valuations prepared for other purposes may be used by tax authorities, and carefully craft responses to IRS information document requests. They note that these day-to-day considerations can have a significant impact on audit outcomes and help avoid protracted disputes.
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