Reflections on the Ninth Circuit’s Decision in Amazon.com, Inc. v. Commissioner What is included when valuing intangibles assets for transfer pricing purposes? This is an issue that was addressed once by the U.S. Tax Court and more recently, the Ninth Circuit Court of Appeals. In a unanimous decision by the U.S. Court of Appeals for the Ninth Circuit (issued on August 16, 2019) the court of appeals affirmed the decision of the U.S. Tax Court in Amazon.com, Inc. v. Commissioner, 148 T.C. 108 (March 23, 2017). The court held that intangible assets under the U.S. transfer pricing regulations, under Section…