On 18 November 2020, an opinion of the U.S. Tax Court was published concerning whether the IRS abused its discretion by making transfer pricing reallocations of royalties by employing a comparable profits method (CMP).
For the years concerned (2007-2009), the Coca-Cola Co. and its domestic subsidiaries ("Coca-Cola") joined in filing consolidated Federal income tax returns. Coca-Cola's foreign manufacturing affiliates ("supply points") had plants in Brazil, Chile, Costa Rica, Egypt, Ireland,…