The government assessed that much in unpaid deficiencies for the years 2007 to 2009, according to filings at the US Tax Court Wednesday, including $837 million in 2007, $844 million in 2008 and $923 million in 2009. That’s on top of interest that has yet to be assessed, according to the filing.
The company has been contesting a transfer-pricing adjustment in Brazil. The government said the company’s affiliates hadn’t paid enough for its intangible property—like trademarks, brand names, and secret formulas—to ...