Amazon.com, Inc. v. Comm'r
United States Tax Court
In 2005 P entered into a cost sharing arrangement (CSA) with S, its Luxembourg subsidiary. Pursuant to the CSA, P granted S the right to use certain pre-existing intangible assets in Europe, including the intangibles required to operate P's European website business. This arrangement required S to make an upfront "buy-in payment" to compensate P for the value of the intangible assets that were to be transferred to S. Seesec. 1.482-7(a)(2), (g)(2), Income Tax Regs.
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In 2005 P entered into a cost sharing arrangement (CSA) with S, its Luxembourg subsidiary. Pursuant to the CSA, P granted S the right to use certain pre-existing intangible assets in Europe, including the intangibles required to operate P's European website business. This arrangement required S to make an upfront "buy-in payment" to compensate P for the value of the intangible assets that were to be transferred to S. Seesec. 1.482-7(a)(2), (g)(2), Income Tax Regs. Thereafter S was required to make annual cost sharing payments to compensate P for ongoing intangible development costs (IDCs), to…
1Opinion of the Court
AMAZON.COM, INC. & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Amazon.com, Inc. v. Comm'r
Docket No. 31197-12
United States Tax Court
2017 U.S. Tax Ct. LEXIS 9; 148 T.C. No. 8;
March 23, 2017, Filed
Decision will be entered under Rule 155.
In 2005 P entered into a cost sharing arrangement (CSA) with S, its Luxembourg subsidiary. Pursuant to the CSA, P granted S the right to use certain pre-existing intangible assets in Europe, including the intangibles required to operate P's European website business. This arrangement required S to make an upfront "buy-in payment" to…
2Cases cited15 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
- Commissioner v. First Security Bank of Utah, N. A.Supreme Court of the United States · 1972
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1991
- Commissioner v. BollingerSupreme Court of the United States · 1988
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