The US Court of Appeals for the Fifth Circuit has ruled, in BMC Software Inc., decided March 13, that accounts receivables created under a transfer pricing closing agreement are not a related-party loans causing partial disallowance of the one-time dividends received deduction for dividends repatriated from controlled foreign corporations between 2003 to 2006. The decision reversed a Tax Court decision in favor of the IRS.
See:
For analysis of the decision, see:
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