- 3 - Glaxo disagrees with the Commissioner’s proposal to increase Glaxo’s taxable income pursuant to section 482 for the years under examination. Since 1994, the applicants have attempted to resolve their differences through the Advance Pricing Agreement Program and through the Internal Revenue Service’s Office of Appeals. In December 1999, Glaxo formally requested relief from double taxation for the taxable years 1989 through 1997 under the mutual agreement procedures (or so-called competent authority process) provided in article 25 of the Convention for the Avoidance of Double Taxation, Dec. 31, 1975, U.S.-U.K., 31 U.S.T. 5668, 5688, as amended by Second Protocol, Apr. 25, 1980, 31 U.S.T. 5707, 5708. The applicants anticipate that the competent authority process could be protracted. The Commissioner has not issued a notice of deficiency to Glaxo for the years under examination. Because of their commitment to the competent authority process, the applicants do not anticipate that the Commissioner will issue a notice of deficiency to Glaxo in the near future. Assuming that the Commissioner issues a notice of deficiency to Glaxo, the applicants expect that the matter will proceed to trial but not until 2005 or 2006. The applicants seek permission to take the depositions of Sir Paul Girolami (Mr. Girolami) and Sir David Jack (Mr. Jack),Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011