Advice to multiple companies on potential tax refunds under the Varian ruling
We are representing clients in refund claims
Davis Polk is advising several clients on the potential for filing refund claims based on the Tax Court’s ruling in the Varian case.
In its August 2024 ruling in Varian Medical Systems v. Commissioner, the Tax Court invalidated a tax regulation and ruled that the taxpayer was entitled to the favorable tax treatment provided by a mismatch in the effective dates of two statutory changes enacted as part of the Tax Cuts and Jobs Act of 2017. At issue is a deduction for domestic corporate parents receiving foreign source dividends from certain 10% owned foreign subsidiaries.
The Davis Polk tax controversy team includes partner Mario J. Verdolini and counsel Christopher A. Baratta. All members of the Davis Polk team are based in the New York office.