BMC Software Loses $13M Repatriation Tax Holiday Fight

Law360, New York (September 19, 2013, 4:03 PM EDT) -- 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...
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