ARTICLE
16 October 2023

Clark Armitage Comments On Dispute Between IRS And Microsoft Over Back Taxes

CD
Caplin & Drysdale
Contributor
Having celebrated our 50th Anniversary in 2014, Caplin & Drysdale continues to be a leading provider of legal services to corporations, individuals, and nonprofits throughout the United States and around the world. We are also privileged to serve as legal advisors to accounting firms, financial institutions, law firms, and other professional services organizations. Please visit www.caplindrysdale.com for more information.
Multinational companies have long used offshore havens to reduce their U.S. tax bills, but the sheer size of Microsoft Corp.'s disclosure that it may owe nearly $29 billion in back taxes has jolted industry experts.
United States Tax
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Multinational companies have long used offshore havens to reduce their U.S. tax bills, but the sheer size of Microsoft Corp.'s disclosure that it may owe nearly $29 billion in back taxes has jolted industry experts.

The technology giant said Wednesday in a securities filing that the Internal Revenue Service has asserted that the company owes $28.9 billion in taxes on its global operations for 2004-2013, plus more for penalties and interest.

. . .

Said J. Clark Armitage, an international tax lawyer at Caplin & Drysdale in Washington, D.C.: "It's a huge number."

. . .

It's not clear what type of penalties Redmond, Washington-based Microsoft might face, but interest could add more than $2 billion to the final bill, Armitage said.

. . .

The agreements are particularly lucrative for companies whose core asset is intellectual property with lucrative royalties, like Microsoft. "All the value in Microsoft is in the IP — that's what gives rise to their profitability," Armitage said

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This article is designed to give general information on the developments covered, not to serve as legal advice related to specific situations or as a legal opinion. Counsel should be consulted for legal advice.

ARTICLE
16 October 2023

Clark Armitage Comments On Dispute Between IRS And Microsoft Over Back Taxes

United States Tax
Contributor
Having celebrated our 50th Anniversary in 2014, Caplin & Drysdale continues to be a leading provider of legal services to corporations, individuals, and nonprofits throughout the United States and around the world. We are also privileged to serve as legal advisors to accounting firms, financial institutions, law firms, and other professional services organizations. Please visit www.caplindrysdale.com for more information.
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