U.S. IRS and Caterpillar settle transfer pricing dispute over royalties

The U.S. IRS and Caterpillar, Inc., on July 31, filed a stipulated settlement, ending their U.S. Tax Court dispute over whether royalty income should be allocated to Caterpillar from the company’s Belgium and French subsidiaries.  Tax Court Docket No. 010790-13, For analysis of the dispute, see post by Jerald David August of Fox Rothschild, LLP.