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News Breaks
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 12, 2014
08:05 EDTDLPHGoldman to hold a conference
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November 10, 2014
06:41 EDTDLPHGM ordered new switches months before recall, WSJ reports
Half a million replacement ignition switches were ordered by General Motors (GM) almost two months before it alerted federal safety regulators of the issues that led to a recall of millions of vehicles, the Wall Street Journal reports, citing email exchanges between the automaker and Delphi Automotive (DLPH). The email exchanges, which took place in mid-December 2013 between a GM contract worker and Delphi, indicate GM placed an "urgent" order for 500,000 replacement switches on December 18, a day after a meeting of senior executives. Reference Link

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