Recent developments in the case of Illinois Tool Works Inc. et al. v. Commissioner (No. 10418-14) (United States Tax Court) were released earlier this month.
The IRS filed a pretrial memorandum with the Tax Court in Illinois Tool Works Inc.’s case challenging a $70 million deficiency, arguing that a distribution received from a controlled foreign corporation was taxable income and that the corporation is liable for an accuracy-related penalty.
In addition, Illinois Tool Works Inc. filed a pretrial memorandum with the Tax Court in its case challenging a $70 million deficiency, arguing that a loan to a shareholder was bona fide debt and that a distribution was properly treated as a nontaxable return of basis.
The filings for the case can be viewed here: Filings and Proceedings, Illinois Tool Works Inc. & Subsidiaries
Posted by Allison Trupp, Associate Editor, Wealth Strategies Journal