Thursday 14th of December 2017 8:13:22 AM

  • US Debt-vs-Equity Dispute Won by PepsiCo Inc

    Thursday 27th of September 2012 9:22:30 AM

    IRS allegedly accused PepsiCo Inc. for not paying their corporate income tax return amounting to USD363m in relation with their subsidiary investments in Netherlands from years 1998-2002.

    IRS filed their complaint in the United States Tax Court however they loss the case to PepsiCo Inc. after Judge Joseph Goeke presented his long and complex 100-page decision stating that the company’s hybrid securities (where their payments originated) could be treated as debt in the Netherlands and also can be characterized as equity for federal tax purposes.


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