Tax Notes | Coca-Cola Case Offers Guidance on Reliance on Closing Agreements

The judicial branch was busy over the summer churning out transfer pricing cases. This article discusses two bellwether transfer pricing decisions defining the Internal Revenue Service’s ability to cancel advance pricing agreements and how the arm’s-length standard applies to high-value intercompany licensing transactions.

Alston & Bird has broadened its transfer pricing and international tax capabilities with the addition of counsel E. Miller Williams, Jr. in the firm’s Atlanta office. Joining from Ernst & Young, where he was a principal, Williams advises multinational companies on complex transfer pricing matters, with an emphasis on international transfer pricing controversy, audits, advance pricing agreements, competent authority, and intercompany planning and structuring.

Ryan Kelly is quoted on how the intricacies of transfer pricing may give rise to Internal Revenue Service disputes over privileged information.

Alston & Bird has expanded its federal and international tax capabilities with the addition of Ryan J. Kelly as partner in the firm’s Washington, D.C., office. Joining from the U.S. Internal Revenue Service, where he served as an attorney-advisor in the Office of Associate Chief Counsel (International), Kelly brings deep experience in tax dispute resolution and general tax planning, with a focus on transfer pricing.