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BMC SOFTWARE, INC. v. C.I.R.

No. 13-60684.

780 F.3d 669 (2015)

BMC SOFTWARE, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

March 13, 2015.

Attorney(s) appearing for the Case

Gwendolyn Johnson Samora , Lina Ginan Dimachkieh , George Matthew Gerachis , Christine L. Vaughn , Vinson & Elkins, L.L.P., Washington, DC, for Petitioner-Appellant.

Ellen Page DelSole, Esq. , Trial Attorney, Jonathan S. Cohen , Kathryn Keneally , U.S. Department of Justice, Washington, DC, Daniel L. Tirnrnons , Internal Revenue Service, Dallas, TX, William J. Wilkins , Internal Revenue Service, Washington, DC, for Respondent-Appellee.

Before REAVLEY, ELROD, and SOUTHWICK, Circuit Judges.

This case involves a decision by the Commissioner of Internal Revenue (Commissioner) to partially disallow BMC Software, Inc.'s (BMC) repatriated-dividends tax deduction under 26 U.S.C. § 965(b)(3) on the ground that subsequently created accounts receivable constituted "indebtedness" and reduced BMC's eligibility...

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