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

November 2011

Overview

Cooper Companies could be the first case dealing with the proper application of the foreign base company sales income branch rule, Thus far, no court case or IRS ruling has directly addressed the branch rule. Therefore, the manner in which the Tax Court analyzes and decides the issues could be of significant importance. In addition, regardless of whether the case is ultimately decided or the result, the case presents an opportunity to gain insights about the IRS position on these issues.

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Doug McHoney
Outbound Co-leader, International Tax Services
Tel: +1 (312) 298 2527
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Calum Dewar
International Tax Outbound Services co-leader
Tel: +1 (646) 471 5254
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