The Resource Hewlett-Packard Company and Consolidated Subsidiaries v Commissioner of Internal Revenue : TC Memo 2012-135
Hewlett-Packard Company and Consolidated Subsidiaries v Commissioner of Internal Revenue : TC Memo 2012-135
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The item Hewlett-Packard Company and Consolidated Subsidiaries v Commissioner of Internal Revenue : TC Memo 2012-135 represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.This item is available to borrow from 1 library branch.
Resource Information
The item Hewlett-Packard Company and Consolidated Subsidiaries v Commissioner of Internal Revenue : TC Memo 2012-135 represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
This item is available to borrow from 1 library branch.
- Summary
- Judgment by the United States Tax Court, dated 14 May 2012. This is the first of a series of foreign tax credit generator cases currently before the US courts. This involved a transaction utilising contingent interest notes. The transaction was originally put together by AIG Financial Products Corp, the Dutch bank ABN was then brought in, and the arrangement was offered to and taken up by Hewlett Packard. The IRS denied the tax credits on several grounds. The only one decided upon by the court was whether the investment by Hewlett Packard was debt rather than equity. This issue is examined at some length by the court, by reference to 11 factors which are indicative of debt or equity. The court applied these factors and concluded that the investment was more properly seen as debt. In those circumstances, there was no entitlement to the foreign tax credit
- Language
- eng
- Label
- Hewlett-Packard Company and Consolidated Subsidiaries v Commissioner of Internal Revenue : TC Memo 2012-135
- Title
- Hewlett-Packard Company and Consolidated Subsidiaries v Commissioner of Internal Revenue : TC Memo 2012-135
- Language
- eng
- Summary
- Judgment by the United States Tax Court, dated 14 May 2012. This is the first of a series of foreign tax credit generator cases currently before the US courts. This involved a transaction utilising contingent interest notes. The transaction was originally put together by AIG Financial Products Corp, the Dutch bank ABN was then brought in, and the arrangement was offered to and taken up by Hewlett Packard. The IRS denied the tax credits on several grounds. The only one decided upon by the court was whether the investment by Hewlett Packard was debt rather than equity. This issue is examined at some length by the court, by reference to 11 factors which are indicative of debt or equity. The court applied these factors and concluded that the investment was more properly seen as debt. In those circumstances, there was no entitlement to the foreign tax credit
- Citation source
- In: International tax law reports. - London. - Vol. 14 (2012),
- http://bibfra.me/vocab/relation/comm
- ihLwW3I1h7k
- http://library.link/vocab/creatorName
- Blessing, P.H
- Language note
- English
- http://library.link/vocab/relatedWorkOrContributorName
- Baker, P
- http://library.link/vocab/subjectName
-
- case law
- foreign tax credit
- debt
- interest
- SPV
- Label
- Hewlett-Packard Company and Consolidated Subsidiaries v Commissioner of Internal Revenue : TC Memo 2012-135
- Label
- Hewlett-Packard Company and Consolidated Subsidiaries v Commissioner of Internal Revenue : TC Memo 2012-135
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/Hewlett-Packard-Company-and-Consolidated/5t-yxODu4x4/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/Hewlett-Packard-Company-and-Consolidated/5t-yxODu4x4/">Hewlett-Packard Company and Consolidated Subsidiaries v Commissioner of Internal Revenue : TC Memo 2012-135</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="https://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
