Tax Court may address certain important Subpart F sales income issues for the first time

January 2012



The Cooper Companies, Inc. and Subsidiaries v. Comm'r, could be the first court decision on the application of the foreign base company salesincome branch rule to a branch with no sales activities. At stake are important issues related to the application of the branch rule. Regardless of the outcome, the case provides insights into the IRS's branch rule positions and could indicate how the IRS may approach other audit examinations.

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