Bruce Ely Quoted in Bloomberg Tax on ConocoPhillips Quietly Settling Louisiana Profit-Shifting Lawsuit

Bradley attorney Bruce Ely was quoted in Bloomberg Tax on the Louisiana Department of Revenue’s recent confidential settlement of a major tax lawsuit against ConocoPhillips Co. The litigation generated attention among many tax practitioners and other revenue agencies as a rare lens into state transfer pricing tax disputes.

Transfer pricing involves the valuation of assets transferred between related enterprises under common control. With the growth of complex, multi-jurisdictional corporate structures, state tax auditors are increasingly monitoring businesses that may use such transactions to shift profits to low- or no-tax jurisdictions. Most transfer pricing controversies are handled without public disclosure, but the Conoco dispute was the rare case that spilled into public view through a lawsuit.

“I don’t know the details, but I suspect the transfer pricing methodology employed by the Louisiana Department of Revenue was found to be totally off base,” said Ely.

The full article, “ConocoPhillips Quietly Settles Louisiana Profit-Shifting Lawsuit,” was published by Bloomberg Tax on September 3, 2024.