HP 'Equity' Was Actually Debt And A Tax Shelter: 9th Circ.

Law360, New York (November 9, 2017, 10:07 PM EST) -- A Ninth Circuit panel Thursday affirmed a tax court’s ruling that Hewlett-Packard Co.’s investment in a Dutch company cannot be treated as equity, which would have allowed it to claim foreign tax credits, but instead should be treated as debt because the intent behind the deal was a tax workaround.

In the unanimous, published decision penned by U.S. Circuit Judge Alex Kozinski, the panel described a complicated set of financial transactions between HP and the Dutch company called Foppingadreef Investments, which was created by AIG with...
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