Bloomberg Tax
April 11, 2019, 8:45 AM

Amazon, IRS Return to Court for $2 Billion Tax Case Appeal

Isabel Gottlieb
Isabel Gottlieb
Reporter Inc. and the IRS will square off in court for a second time in a dispute involving more than $2 billion in tax adjustments the agency imposed on the company for its international tax arrangements.

In April 12 oral arguments before the Ninth Circuit, the Internal Revenue Service is appealing a 2017 U.S. Tax Court decision in Amazon’s favor, in a dispute over the value of intangibles—such as intellectual property, patents, and trade names—that Amazon transferred to its European business in Luxembourg.

The IRS had adjusted Amazon’s tax liability for 2005 and 2006 by $2.2 billion, arguing that Amazon ...

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