Texas Instruments Fights $48 Million Foreign Intangible Tax Bill

Prominent global producer of analog semiconductors Texas Instruments, Inc., is suing the IRS, alleging the agency incorrectly adjusted its deductions taken for foreign-derived intangible income.

As a result of erroneous adjustments to its IRC Section 250 deductions, Texas Instruments faces $9.6 million and $38.3 million deficiencies for the 2018 and 2019 tax years respectively, the petition filed with the US Tax Court said. The company seeks an overpayment refund for both years at issue.

Section 250 deductions, enacted by a 2017 congressional Republican spending package, allow domestic C corporations to claim deductions on certain income from foreign ...