AIG Says IRS Misstated District Court Findings, Raises New Arguments

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Oct. 15 —  In an appeals brief, American International Group Inc. disagreed with the Internal Revenue Service's contention that there were disputed facts regarding AIG transactions with foreign banks for which the company claimed foreign tax credits (Am. Int'l Group, Inc. v. United States, 2d Cir., No. 14-00765, brief filed 10/14/14).

AIG filed its reply brief Oct. 14 in the U.S. Court of Appeals for the Second Circuit. AIG is appealing an interlocutory order by the U.S. District Court for the Southern District of New York.

In March 2013, Judge Louis L. Stanton denied AIG's motion for partial summary judgment that it was entitled to credits for foreign taxes paid by affiliates on income generated in relation to the sale of preferred stock to foreign banks (64 DTR K-1, 4/3/13).