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Avi-Yonah: Xilinx Revisited

Tax Analysts Reuven S. Avi-Yonah (Michigan) has published Xilinx Revisited, 126 Tax Notes 1621 (Mar. 29, 2010). Here is the abstract:

In this article, Avi-Yonah argues that the original Xilinx panel decision was correct and that the new one was the result of the government's refusal to accept the rationale of that decision. However, he also believes that [although] taxpayers have won another transfer pricing battle, they could lose the war if Congress decides to adopt the budget proposals on transfers of intangibles.

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