Siemens Disputes $315 Million Tax Deduction Cut for Dividends

The IRS wrongly cut $315 million in foreign dividend tax deductions to Siemens Medical Solutions USA Inc., it told the US Tax Court, asking that court to follow the precedent in a recent case that ruled against the IRS.

Siemens petitioned the Tax Court to contest the disallowance for its 2019 and 2021 tax returns, which resulted in about $7 million in tax deficiencies attributed to the company for the two years.

The dispute arises from a credit claimed under IRC Section 245A, which allows a deduction for the foreign-source portion of dividends. It follows a Tax Court ...