March 16, 2015
The Fifth Circuit on Friday overturned a decision by the U.S. Tax Court that upheld a $13 million tax deficiency imposed by the Internal Revenue Service on a software company, saying a foreign subsidiary's debt did not exist for purposes of the law.
September 03, 2014
BMC Software Inc. told a Houston-based panel of the Fifth Circuit on Wednesday that it shouldn't have to pay a $13 million tax assessment because the IRS unfairly reduced a deduction the company took under a law that allowed it to repatriate overseas cash at a reduced tax rate.