107 The section says nothing, however, to guide courts in determining where clever business practice stops and tax evasion or income distortion begins. ... either tax evasion or distorted reflection of the parent companya#39;s income as a result of the subsidiary operation.aquot;4 One case in which tax evasion was established is E.I. Du Pont de Nemours and Co. v. ... United States, 608 F.2d 445 (Ct. Cl. 1979). 1 16.
|Title||:||Hastings International and Comparative Law Review|