http://www.taxgirl.com/landmark-transfer-pricing-case-is-it-a-different-world/ Paying taxes is painful... but reading about them shouldn't be. Sun, 12 Feb 2012 17:55:29 +0000 hourly 1 http://wordpress.org/?v=3.1.3 http://www.taxgirl.com/landmark-transfer-pricing-case-is-it-a-different-world/comment-page-1/#comment-13102 CWA Fri, 11 Dec 2009 04:47:43 +0000 http://www.taxgirl.com/?p=3423#comment-13102 The R&D must have been capitalized else this would've lowered profits in Ireland...right? The R&D must have been capitalized else this would’ve lowered profits in Ireland…right?

]]> http://www.taxgirl.com/landmark-transfer-pricing-case-is-it-a-different-world/comment-page-1/#comment-10505 JBruce Fri, 29 May 2009 19:19:03 +0000 http://www.taxgirl.com/?p=3423#comment-10505 What Xilinx did was to transfer some profits to a low-tax environment while keeping (deductible) expenses in a high-tax environment. I guess the IRS was trying to say you can't have it both ways. Whatever the arguments are, I'm sure they're arcane and not all that entertaining for us observers to watch and listen to. I guess Congress needs to clarify this. Not that they ever will, but the confusions of multi-national corporate operations so need some clarification. What Xilinx did was to transfer some profits to a low-tax environment while keeping (deductible) expenses in a high-tax environment. I guess the IRS was trying to say you can’t have it both ways. Whatever the arguments are, I’m sure they’re arcane and not all that entertaining for us observers to watch and listen to.
I guess Congress needs to clarify this. Not that they ever will, but the confusions of multi-national corporate operations so need some clarification.

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