Tyco International is latest taxpayer to challenge IRS on debt-equity in US Tax Court

Joe Dalton

August 14, 2013

Fire protection and security company Tyco International is taking on the Internal Revenue Service (IRS) in the US Tax Court after the tax authority tried to re-characterise intra-group financing transactions as equity, rather than debt, instruments.

Unlock this article.

The content you are trying to view is exclusive to our subscribers.

To unlock this article:

Take a Free Trial or Login

More from across our site

Amsterdam Netherlands dancing houses over river Amstel landmark

TP decree reinforces shift in Dutch tax policy

The Dutch TP decree marks a turn in the Netherlands as the country aligns its tax policies with OECD standards over claims it is a tax haven.

Leanna Reeves, August 11, 2022

Q&A: Lexmark VAT leader talks inflation and tax strategy

Gorka Echevarria talks to reporter Siqalane Taho about how inflation, e-invoicing and technology are affecting the laser printing firm in a post-COVID world.

Siqalane Taho, August 10, 2022

Tax data security now high priority amid digitisation drive

Tax directors have called on companies to better secure their data as they generate ever-increasing amounts of information due to greater government scrutiny.

Siqalane Taho, August 10, 2022

Female hand with megaphone on white background

Last call to comment on Australia-India tax treaty

Incoming amendments to the treaty could increase costs on non-resident Indian service providers.

Danish Mehboob, August 08, 2022

Target shot opportunity dartboard performance how accurate can it be win looser miss fail flunk throw loss failure score on white background competition archery isolated 3d illustration

US corporate tax ‘not even close’ to pillar two

Experts say the proposed minimum tax does not align with the OECD’s pillar two regime and risks other countries pulling out.

Danish Mehboob, August 08, 2022

This week in tax: Malawi seeks $310bn in unpaid taxes from US mining company

The Malawian government has targeted US gemstone miner Columbia Gem House, while Amgen has successfully consolidated two separate tax disputes with the Internal Revenue Service.

Danish Mehboob, August 05, 2022

ITR Summer Issue 2022: Editorial

ITR's latest quarterly PDF is now live, leading on the rise of tax technology.

Ed Conlon, August 05, 2022

ITR Americas Tax Awards 2022: shortlist announced

ITR is delighted to reveal all the shortlisted firms, teams, and practitioners for the 2022 Americas Tax Awards – winners to be announced on September 22

John Harrison, August 04, 2022

LONDON, UK - January 24th 2019: HMRC, Her Majesty's Revenue and

Carelessness will be costly under UK’s new TP regime: sources

‘Care’ is the operative word as HMRC seeks to clamp down on transfer pricing breaches next year.

Leanna Reeves, August 04, 2022

Companies advised to fix Canadian tax insurance policies

Tax directors tell ITR that the CRA’s clampdown on unpaid taxes on insurance premiums is causing uncertainty for businesses as they try to stay compliant.

Siqalane Taho, August 03, 2022