Open Access. Powered by Scholars. Published by Universities.®

Business Commons

Open Access. Powered by Scholars. Published by Universities.®

California Polytechnic State University, San Luis Obispo

Series

Transfer-pricing

Publication Year

Articles 1 - 2 of 2

Full-Text Articles in Business

Apple’S Cost-Sharing Arrangement: Frankenstein’S Monster, David G. Chamberlain, Stephen L. Curtis Aug 2021

Apple’S Cost-Sharing Arrangement: Frankenstein’S Monster, David G. Chamberlain, Stephen L. Curtis

Accounting

In this two-part report, Curtis and Chamberlain break down Apple’s cost-sharing arrangement and explain how corporate taxpayers have been able to exploit the cost-sharing regulations to shift hundreds of billions or even trillions in U.S. profits offshore with little or no IRS detection or enforcement.


How The Tax Court Can Account For Risk In Medtronic Transfer Pricing, David G. Chamberlain Aug 2020

How The Tax Court Can Account For Risk In Medtronic Transfer Pricing, David G. Chamberlain

Accounting

In this report, Chamberlain explores how the Tax Court, on remand in Medtronic, can address the challenge of determining arm’s-length transfer prices when one of the related parties bears substantial risk but owns no valuable intangible property.