Lee A. Sheppard (Contributing Editor, Tax Analysts) has published Industry Practice as the Arm’s-Length Method, 109 Tax Notes 438 (Oct. 24, 2005), also available on the Tax Analysts web site as Doc 2005-21364, 2005 TNT 205-10. The article examines the potential effect of the Tax Court’s decision in Xilinx Inc. v. Commissioner, 125 T.C. No. 4 (Aug. 29, 2005), on the IRS’s rules for cost-sharing agreements.
