Western Union Sues IRS Over Adjusted Intangible Tax Obligations

The Western Union Co. accused the IRS of incorrectly and retroactively adjusting its tax obligations after the agency determined the company couldn’t exclude a Bermuda subsidiary from its revenue.

The financial services firm petitioned the US Tax Court in response to the IRS adjusting its global intangible low-taxed income, or GILTI, by $8.2 million for its 2018 fiscal year. This calculation brought the company’s GILTI inclusion to $728,000, resulting in a tax deficiency of over $80,000, according to the petition.

The IRS improperly relied on a revenue procedure that was published without the proper notice and comment and which exceeded ...