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US Sixth Circuit rules in favor of Eaton in appeal from Tax Court regarding APA cancellation

|Tax Alerts, National/Federal Taxation, Transfer Pricing, Legislation & Policy|United States, Dominican Rep, Puerto Rico
United States, Dominican Rep, Puerto Rico

  • On 25 August 2022, the Sixth Circuit issued its decision in Eaton Corp. v. Commissioner, ruling in favor of Eaton Corporation.

  • The Sixth Circuit held that the Internal Revenue Service (IRS) had the burden of proving that it had grounds to cancel the Advance Pricing Agreements (APAs) under contract-law principles and failed to do so.

  • The Sixth Circuit ruled that the IRS forfeited its penalties claim by basing its post-trial claim on a new assessment.

Executive summary

On August 25, 2022, the United S…

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