The IRS’s #transferpricing power is being tested. After a federal appeals court sided with 3M Co., limiting how the IRS can apply Section 482, all eyes are on Coca-Cola and its $18 billion dispute over #royaltypayments to international affiliates. In Bloomberg Tax, Exactera COO Mimi Song shares her perspective on how the 3M decision could influence Coca-Cola’s case, why key differences between the two matter, and why the differences between the two may lead to very different outcomes. Read the full article: https://lnkd.in/gcR5rm-b
