Aventis Owes $38.5 Million as Tax Court Rejects Financing Tool

Pharmaceutical company Aventis Inc. and its subsidiaries owe about $38.5 million in taxes for 2008-2011, the US Tax Court said Wednesday, rejecting the use of a now-repealed structure that provided tax benefits for inter company financing.

The structure, known as a Financial Asset Securitization Investment Trust or FASIT, was designed to allow companies to securitize non-mortgage debt obligations. Aventis’s arrangement didn’t qualify because a key component, the “Series A/E Stock,” failed to meet the statutory requirements for a regular interest in a FASIT, the court said.

Pennsylvania-based Aventis is an indirect subsidiary of its French parent company, Sanofi SA, which ...