The US Tax Court has held that accounts receivable that were established as transfer pricing adjustments constitute increased related-party indebtedness, reducing the amount qualifying for a dividends received deduction (DRD) under section 965 of the US Internal Revenue Code (IRC) (BMC Software Inc. v. Commissioner of Internal Revenue, 141 T.C. No. 5, Docket No. 15675-11, 18 September 2013).
The case involved a US corporation that repatriated funds from its wholly owned controlled for…