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Contract analysis / email-cross-to-iyer-financial-impact-20240319.eml
email-cross-to-iyer-financial-impact-20240319.eml
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Medium · 1
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1. Execution of IRS Form 906 (Closing Agreement) — we anticipate this can be completed pro
1. Execution of IRS Form 906 (Closing Agreement) — we anticipate this can be completed promptly following acceptance.
2. Filing of amended federal income tax returns (Forms 1120X) for TY 2017–2020 to reflect
2. Filing of amended federal income tax returns (Forms 1120X) for TY 2017–2020 to reflect the adjustments; we will provide detailed filing instructions and draft the amended returns.
3. Interest payment, to be made concurrently with or following execution of the closing ag
3. Interest payment, to be made concurrently with or following execution of the closing agreement.
4. State tax implications (New Jersey and other filing states) are being analyzed separate
4. State tax implications (New Jersey and other filing states) are being analyzed separately; a memo from our team will follow within the next two weeks.
5. Irish tax consequences — Leila Nazari on our team is coordinating with Ciarán Thornbury
Medium
⚑ Confidentiality undertaking
5. Irish tax consequences — Leila Nazari on our team is coordinating with Ciarán Thornbury at Thornbury & Keogh regarding any impact on PBI's Irish tax position, including the Knowledge Development box claims. I am happy to schedule a follow-up call with you, Marcus, Deborah, and Catherine Falk if that would be helpful before management makes its final decision. We view this as an excellent result that resolves a sig