Molly Moses

An expert witness for the Internal Revenue Service questioned the financial projections prepared by Eaton Corp.'s experts Friday in U.S. Tax Court, saying the data they relied on wasn't available in 2012, when the company took on debt to acquire Ireland-based Cooper Industries, a global electrical products manufacturer, for $13 billion.

An accounting expert and a former Eaton Corp. official both advised the U.S. Tax Court on Thursday about the data used to establish the financial position of the U.S. company after its acquisition of Irish-based Cooper Industries in 2012.

When it acquired Ireland-based Cooper Industries in 2012, Eaton Corp. should have considered the costs of borrowing in Europe to finance the transaction, Tax Court Judge Albert Lauber said Friday in questioning a former Eaton official.

A U.S. Tax Court judge questioned a former Eaton Corp. official Wednesday about the company's decision to restructure the ownership of a valuable foreign subsidiary when it inverted in 2012, noting that the move placed a $14 billion asset out of the U.S. company's reach.

Eaton Debt Analysis Must Trace Distinct Steps, Tax Court Told

An attorney for Eaton Corp. told the U.S. Tax Court on Monday that the interest rates and guarantee fees the company paid to its newly formed Irish parent in 2012 must be analyzed as a set of distinct steps, beginning with determing a standalone credit rating for the U.S. company — an analysis a government attorney said was "needlessly elaborate."

Eaton Corp.'s former chief financial officer chronicled on Tuesday the company's efforts to finance its 2012 acquisition of Ireland-based Cooper Industries, describing an atmosphere of leery bond investors after the Great Recession of 2008, on the second day of the company's U.S. Tax Court trial.

Eaton is preparing to defend the interest rates and guarantee fees paid by entities in the U.S. to their newly formed Irish parent after the company's 2012 acquisition and inversion at a U.S. Tax Court trial scheduled to start Nov. 3.

Eaton is preparing to defend the interest rates and guarantee fees paid by entities in the U.S. to their newly formed Irish parent after the company's 2012 acquisition and inversion at a U.S. Tax Court trial scheduled to start Nov. 3.

Eaton is preparing to defend the interest rates and guarantee fees paid by entities in the U.S. to their newly formed Irish parent after the company's 2012 acquisition and inversion at a U.S. Tax Court trial scheduled to start Nov. 3.

Latin American countries, especially Brazil, are concerned that the deal announced by the Group of Seven countries in June exempting U.S. multinationals from a globally agreed 15% minimum tax gives the U.S. an unfair advantage over them, a professor at University of Antwerp said Monday.

Columbia University professor and economist Joseph Stiglitz met with officials from Spain and Chile on Wednesday at an event that called for tax policies to rein in extreme wealth.

Finland's government has proposed amending the way the country's tax administration accesses certain financial information, such as bank records, in order to narrow and better target the information requests in line with European Union data privacy standards, the administration said Thursday.

The European Union's Economic and Financial Affairs Council on Friday approved recommendations put forward in July for tax incentives to promote clean technologies and industry. 

The European Commission presented a proposal Friday for changing the directive on tobacco taxation to the Economic and Financial Affairs Council, seeking to raise minimum tax rates, subject more products to minimum taxes and apply the bloc's existing electronic system for monitoring movement of goods to raw tobacco.

A U.S. Tax Court judge has been sent back to the drawing board once again in the long-running transfer pricing litigation brought by Medtronic, raising questions about how much weight the court must give to IRS transfer pricing regulations and how much authority it has to go its own way.

Michael McDonald, who retired from EY last month, spent most of his career at the U.S. Treasury Department, working on rules governing how related companies should calculate the value of intangible assets transferred between them, then later contributed to the massive rewrite of international tax rules by the OECD in 2015. McDonald reflected on both projects in an interview with Law360.

What do tax professionals read in their spare time? A wide variety of books, it turns out. Here, Law360 looks at the books enjoyed by tax lawyers, professors and analysts who spoke with Law360.

The IRS is taking an "extreme" position in its defense of a $2.7 billion tax ruling against Coca-Cola by asserting that the standard prohibiting arbitrary and capricious actions by an agency doesn't apply to it, the company told the Eleventh Circuit.

Canada's Department of Finance is considering changes to legislation that outlines the tax authority's power to recharacterize transactions set forth in contracts between related parties when their behavior doesn't match what the contract says, an official said Thursday.