On October 28, 2019, the U.S. Tax Court released a supplemental opinion regarding Eaton Corporation’s recent win in Eaton Corp. & Subs. V. Commissioner, T.C. Memo 2017.
This case could raise concerns regarding the compliance certainties of Advance Pricing Agreements (APAs), and whether APAs are worthwhile considering the process of obtaining an them is time-consuming and expensive.
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