Main Issue:
Intercompany Transactions / Gross Receipts
Facts:
Taxpayer excluded intercompany gross receipts including transactions with foreign members
IRS argued that only QREs, not gross receipts, were to be disregarded
Conclusion:
The court sided with the taxpayer, both types of intercompany transactions should be disregarded
Take-Away Point:
When computing credits, needs to evaluate and understand any intercompany relationships and transactions
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