Overview
Bloomberg Tax quoted Steve Dixon in an article about the most anticipated transfer-pricing cases that will be litigated in the coming year. The article—"Major Firms Seek to Shift Transfer Pricing Law Landscape in 2024"—discusses litigation between multinationals and tax authorities in the US, Australia, and Canada. The article focuses on those high-stakes cases with the potential to alter the transfer-pricing landscape for multinationals.
Speaking about what is now the IRS’s second appeal from the Tax Court in Medtronic Inc. v. Commissioner, Dixon remarked on what is at stake in the Eighth Circuit’s review of the unspecified method that the taxpayer put forward and the Tax Court blessed (albeit with adjustments).