Overview
On July 15, 2022, Law360 quoted Matthew Frank in a piece titled "International Tax Cases To Watch In The Second Half Of 2022." The article examines eight of the most-important international tax cases to monitor this year.
Regarding Coca-Cola Co. et al. v. Commissioner of Internal Revenue, a transfer pricing case involving Coca-Cola, Frank is paraphrased as saying that "Coca-Cola's publicly reported reserves seem to signal that the company has a lot of confidence in its transfer pricing arguments." He is then quoted that "The reserves seem to reflect a high degree of confidence that the adjustments are going to be set aside — not just for the years in litigation, but for subsequent years."
The full article can be read at Law360 (subscription required).