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Douglas Stransky was quoted in the article “Top International Tax Cases to Watch In 2026,” published by Law360 Tax Authority [sub. req'd] on January 2, 2026. The article examines several high-stakes international tax disputes expected to shape the legal landscape in the coming year, including transfer pricing challenges involving Coca-Cola, McKesson and Medtronic, as well as questions surrounding the government’s regulatory authority and the application of the economic substance doctrine.

Commenting on McKesson’s challenge to IRS cost-sharing regulations, Doug noted that the statute of limitations should begin when the taxpayer is harmed by the regulation, rather than when the regulation was first issued. He pointed to the U.S. Supreme Court’s 2024 decision in Corner Post v. Board of Governors of the Federal Reserve System as support for McKesson’s position, saying the ruling “seems very promising to McKesson’s contention that its case is not time-barred.”

Doug also weighed in on Coca-Cola’s long-running transfer pricing dispute, observing that the company did not experience factual changes in its core business operations that would justify the IRS’s retroactive shift in pricing methodology. “I could see where the IRS might say it in an audit on a prospective basis, but that’s not what they did,” he said. “They did retroactive, and that’s even worse.”