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In November 2020, the US Tax Court released its opinion in Coca-Cola v Commissioner. If the Tax Court decision is upheld on appeal, it will join the Internal Revenue Service (IRS) victory in Altera Corp. v Commissioner as a rare win for the government in a transfer pricing (TP) case. The Tax Court upheld $9.8 billion in TP adjustments, while giving Coca-Cola credit – over the IRS’s objection – to $1.8 billion in dividend offsets. Coca-Cola’s foreign operations were structured through supply points, which manufactured soft drink concentrate, and service companies or ServCos, which pe...

Each of these distinct attacks had two things in common: China and Super Micro Computer Inc., a computer hardware maker in San Jose, California. They shared one other trait; U.S. spymasters discovered the manipulations but kept them largely secret...

Bloomberg Wants You To Believe in its Mythical Supermicro Spy Chips Feb 12, 2021 10:11 EST Remember when Bloomberg claimed that motherboard supplier Supermicro (NASDAQ:SMCI) had Trojan Horse clandestine chips from China planted on its boards that made their way into the servers of some of the world’s top technology companies? Remember when the company’s stock crashed, a Congressional inquiry was called, and then nothing happened? Well, Bloomberg is doubling down on that story and has brought it back with new, juicy allegations.  Bloomberg says that its new reporting on Supermicro, ...

Bloomberg Revisits their 2018 Story titled 'The Big Hack' in an updated report titled 'The Long Hack: How China Exploited a U.S. Tech Supplier'   In October 2018, Bloomberg posted a controversial report titled "The Big Hack," that was about how China used a tiny chip to infiltrate America's top companies like Apple and Amazon. Apple wasted no time in denying that they were hacked. Apple had even released a full press response wherein they noted that over the course of the past year, Bloomberg had contacted them multiple times with claims, sometimes vague and sometimes elaborate, of an allege...