Bloomberg Law Quotes Chaim Stern on IRS Economic Substance Doctrine in Transfer Pricing

Alston & Bird partner Chaim Stern was quoted in a Bloomberg Law article, "South Africa Accepting APA Applications: Transfer Pricing Report" (subscription required), discussing the IRS's Sixth Circuit appeal in the Perrigo transfer pricing case. Chaim discussed key issues in the case, including whether the court should evaluate a challenged transaction in isolation or consider the overall circumstances surrounding it. "That question of whether you look at the isolated transaction or you look at the overall circumstances surrounding it is pretty critical," Chaim said. "I think a decision in this case one way or the other would be impactful."