India, June 23 -- The Coca-Cola Company (KO) is taking its long-running tax battle with the Internal Revenue Service to a federal appeals court in Miami, seeking to overturn a tax assessment that could exceed $20 billion.
The dispute focuses on how Coca-Cola and its overseas subsidiaries reported profits from 2007 to 2009 under transfer-pricing arrangements. The case centers on a 1996 agreement with the IRS that governed how profits from the company's international operations were allocated.
Coca-Cola licenses key intellectual property, including beverage formulas, trademarks and brand names, to foreign subsidiaries that produce concentrates for international markets.
The company said it followed a "10-50-50" profit-allocation approach u...