Skadden represented Amazon.com, Inc. in a victory against the IRS involving one of the largest transfer pricing cases in decades and the first involving e-commerce. At issue in the case was the determination of the proper tax due upon Amazon's creation of a European headquarters. In rejecting the IRS' attempt to assert over a billion dollars of additional tax liability, the court ruled that the IRS' approach was "arbitrary, capricious and unreasonable."
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