Tax Dispute Over Coca-Cola's Non-U.S. Trademarks Explained

The U.S. Internal Revenue Service (IRS) and Coca-Cola are locked in a battle regarding the proper allocation of income between Coca-Cola and its foreign affiliates pursuant to trademark and trade secret licences. However, the IRS seems to have overlooked a significant economic component of the licence agreement by not recognising the benefit that Coca-Cola receives in the form of more valuable foreign trademark rights.

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