The IRS incorrectly assessed a $1.2 billion tax deficiency to an international medical device manufacturer, failing to properly analyze profits from Swiss and Dutch entity sales under the tax code, the company told the US Tax Court.
Varian Medical Systems Inc. said the IRS erred in “recharacterizing” its 2021 Subpart F income earned by a controlled foreign corporation because the government wrongly decreased Varian’s dividends received and dividends-received deduction under IRC Section 245A, according to a Feb. 6 petition.
Varian manufactures medical devices and software for treating cancer and other medical conditions with radiotherapy and other cancer-fighting tools, according ...