IRS takes on Tyco in U.S. Tax Court debt-vs-equity dispute

By Patrick Temple-West WASHINGTON (Reuters) – A U.S. Tax Court fight between Tyco International Ltd and the Internal Revenue Service reflects a growing assertiveness by the agency over deductibility of interest in certain intercompany financing deals, tax lawyers said on Wednesday. Tyco is challenging a $1 billion tax bill assessed by the IRS based on its view that cash transfers carried out within the multinational company were not debt payments, but taxable dividends, according to U.S. Tax Court documents. …