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On August 21, 2009, Baker & McKenzie LLP filed an amicus brief, on behalf of COT and several other associations, with the Ninth Circuit Court of Appeals in support of the Petition for Rehearing filed by Xilinx Inc.
This case relates to the "arm's length standard" of section 482 of the Internal Revenue Code - which serves as a core principle of international transfer pricing agreements. The brief argues for the affirmation of the “arms length standard” as well as affirmation of the lower court’s (Tax Court) opinion.
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