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June 27, 2014
06:22 EDTDLPHDelphi Automotive says IRS wants company to be treated as domestic
Delphi Automotive disclosed last night that the IRS issued a Notice of Proposed Adjustment asserting that it believes Section 7874(b) applies to Delphi and that the company should be treated as a domestic corporation for U.S. federal income tax purposes, retroactive to October 6, 2009. "If we are treated as a domestic corporation for U.S. federal income tax purposes, we would be subject to U.S. federal income tax on our worldwide taxable income, including distributions, as well as deemed income inclusions from some of our non-U.S. subsidiaries," Delphi said. It added, "Notwithstanding the issuance of the NOPA, we continue to believe, after consultation with counsel, that Delphi should not be treated as a domestic corporation for U.S. federal income tax purposes. We intend to vigorously contest the conclusions reached in the NOPA through the IRSís administrative appeals process, and, if we are unable to reach a satisfactory resolution with the IRS, through litigation. Accordingly, we will continue to prepare and file our financial statements on the basis that we are UK tax-resident. We have not recorded any adjustments with respect to this matter, nor will we record any adjustments in connection with receiving the NOPA. If we are unsuccessful in contesting the IRSís assertion, we would not expect a material cumulative impact to our historical tax position at this time. However, we expect any unfavorable final outcome to adversely impact our tax position by increasing our annualized effective tax rate to approximately 20% to 22%. For the year ended December 31, 2013, our effective tax rate was 17%."
News For DLPH From The Last 14 Days
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November 18, 2015
12:02 EDTDLPHBorgWarner has de-risked set up into Detroit Auto Show, analyst says
Shares of BorgWarner (BWA), a global automotive industry components and parts supplier, are gaining after Goldman Sachs analyst Patrick Archambault upgraded the company to Buy from Neutral citing the 35% pullback in shares since the March 3 peak and improving China sales. WHAT'S NEW: Archambault, who maintained a $54 price target on BorgWarner shares, said in a note to investors that the auto parts maker has de-risked the set up into the Detroit Auto Show in January in the wake of its recent guide down for 2015 and pull forward of backlog cut announcement. The company may get to mid-to-high single digit growth even with a backlog cut and improving China sales "may even point to some upside," the analyst continued. WHAT'S NOTABLE: On November 10, BorgWarner finalized its acquisition of Remy International, a manufacturer of rotating electrical components such as alternators, starter motors and electric traction motors for the automotive and commercial vehicle industry. "With this acquisition, the complementary combination of technologies and global operations will strengthen BorgWarner's product leadership position," said BorgWarner President and Chief Executive Officer James Verrier. On October 30, RBC Capital downgraded BorgWarner to Sector Perform from Outperform with a $45 price target on shares. Analyst Joseph Spak said BorgWarner's story is transitioning from a growth story to GARP as it enters a mid-single digit growth phase, and expects the shareholder base will likely churn and credibility has to be rebuilt. PRICE ACTION: Shares of BorgWarner are advancing 4.79%, or $1.94, to $42.55 in midday trading. OTHERS TO WATCH: Other companies in the space including Lear (LEA), Delphi Automotive (DLPH) and Magna International (MGA) are trading higher in midday trading.
07:57 EDTDLPHBarclays to hold a conference
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