The Resource Tax Court reverses course after 'BMC Software' win in Fifth Circuit : Rev. Proc. 9932 Accounts receivable do not constitute related party indebtedness for purposes of Section 965

Tax Court reverses course after 'BMC Software' win in Fifth Circuit : Rev. Proc. 9932 Accounts receivable do not constitute related party indebtedness for purposes of Section 965

Label
Tax Court reverses course after 'BMC Software' win in Fifth Circuit : Rev. Proc. 9932 Accounts receivable do not constitute related party indebtedness for purposes of Section 965
Title
Tax Court reverses course after 'BMC Software' win in Fifth Circuit : Rev. Proc. 9932 Accounts receivable do not constitute related party indebtedness for purposes of Section 965
Creator
Subject
Language
eng
Summary
The article provides an insight in the background of the decision in case Analog Devices, Inc. v. Commissioner (147 T.C. No. 15, 22 November 2016) in which the US Tax Court has held that accounts receivable that were established as a result of transfer pricing adjustments did not constitute a retroactive increase in related party indebtedness, and thus did not reduce the amount qualifying for a dividends received deduction under Section 965 of the US Internal Revenue Code (IRC)
Citation source
In: Tax management international journal. - Arlington. - Vol. 46 (2017), no. 4 ; 12 p
http://library.link/vocab/creatorName
  • Monahan, M.E
  • Nicholas, D.R.B
  • McKay. K.S
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing adjustment
  • CFC
  • dividend deduction system
  • case law
Label
Tax Court reverses course after 'BMC Software' win in Fifth Circuit : Rev. Proc. 9932 Accounts receivable do not constitute related party indebtedness for purposes of Section 965
Instantiates
Publication
Label
Tax Court reverses course after 'BMC Software' win in Fifth Circuit : Rev. Proc. 9932 Accounts receivable do not constitute related party indebtedness for purposes of Section 965
Publication

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