BMC Software Loses $13M Repatriation Tax Holiday Fight

Law360, New York (September 19, 2013, 4:03 PM ET) -- The U.S. Tax Court on Wednesday upheld a $13 million tax assessment against BMC Software stemming from the 2004 corporate income repatriation tax holiday, saying in a case of first impression that a later IRS settlement that increased its accounts receivable from a foreign subsidiary decreased its deduction. 

The dispute arose out of BMC's claim that $709 million of $721 million brought into the U.S. was subject to a dividends-received deduction under George W. Bush's 2004 tax repatriation holiday, and also out of a later transfer...
To view the full article, take a free trial now.
Try Law360 for free for seven days
Already a subscriber? Click here to login

Already have access?

  1. Forgot your password?
  2. Sign In

Get instant access to the one-stop news source for business lawyers

Required

Sections

Law Firms Mentioned

Companies Mentioned

Government Agencies Mentioned

Related Articles