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Delphi Defends U.K. Tax Base
Delphi Automotive plc says it will "vigorously" defend its British tax base against claims by the Internal Revenue Service that the company must file taxes in the U.S. as a domestic company.
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Delphi Automotive plc says it will "vigorously" defend its British tax base against claims by the Internal Revenue Service that the company must file taxes in the U.S. as a domestic company.
The IRS contends that Delphi remains an American company because its assets were sold to Delphi Holdings LLP after its bankruptcy reorganization in 2009.
But the company, which filed U.S. tax returns through 2011, notes that Delphi Automotive plc and its Delphi Automotive LLP subsidiary both are incorporated in the U.K. As such, it argues, neither company qualifies as a domestic corporation for U.S. tax purposes.
Delphi is among several American companies under pressure from the IRS and the Obama administration for so-called inversion arrangements that sidestep U.S. taxes.
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