Claims Court: Transfer pricing regulations bar amended return that would reduce taxable income

May 2012


Citing the "plain meaning" of one provision of the section 482 transfer pricing regulations, the U.S. Court of Federal Claims has held that the regulations prohibit a taxpayer from making any changes to the computation of transfer prices on an amended return if those changes would reduce the taxpayer's taxable income. The taxpayer, Intersport Fashions West (Intersport), has appealed the decision to the U.S. Court of Appeals for the Federal Circuit.

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