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Article: New York City Tribunal Decision in Toys "R" Us-NYTEX Confirms Arm's Length Pricing As Key to Combination.(The New York City Tax Appeals Tribunal)(The New York City Department of Finance)
- Article from:
- Mondaq Business Briefing
- Article date:
- April 27, 2004
CopyrightCOPYRIGHT 2004 Mondaq Ltd. This material is published under license from the publisher through the Gale Group, Farmington Hills, Michigan. All inquiries regarding rights should be directed to the Gale Group. (Hide copyright information)
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The New York City Tax Appeals Tribunal recently issued what may be the most significant taxpayer victory in New York to date on when the New York tax authorities may forcibly combine a corporate taxpayer with an affiliated intangibles holding company. In Matter of Toys "R" Us-NYTEX, Inc., TAT(E) 93-1039(GC) (N.Y.C. Tax App. Trib., Jan. 14, 2004), the New York City Tribunal ("City Tribunal") held that Toys "R" Us-NYTEX, Inc. ("Toys-NYTEX") proved that its transactions with its affiliated intangibles companies - principally royalty payments for the use of trademarks held by Geoffrey, Inc. ("Geoffrey") and interest payments made to affiliated financing companies - were at ...
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