
IRS Victory: 3M Transfer Pricing Challenge Update
Tax Notes Talk
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The Coca-Cola Decision and the 3M Decision?
3M's failure to meet three requirements, which the tax court upheld as valid, that decided the case in 3M. A lot of taxpayers have encountered this issue with blocked income in Brazil, specifically royalty income. The validity of that was not specifically examined in 3M, and that could come up in subsequent cases, including Coca-Cola.
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