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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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August 14, 2014
17:27 EDTDLPHAppaloosa gives quarterly update on stakes
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10:05 EDTDLPHOn The Fly: Analyst Initiation Summary
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August 13, 2014
16:16 EDTDLPHDelphi Automotive initiated with an Outperform at Credit Suisse
Target $83.
August 11, 2014
15:23 EDTDLPHJPMorgan to hold a conference
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