Day 3 of Illinois Tool Works


Caroline Ngo, representing the taxpayer in a US Tax Court trial involving an IRS challenge to a global manufacturing company’s debt-equity repatriation of cash, asked an expert witness how common it is for holding companies to be publicly traded and to issue and repay debt. The expert replied that holding companies are very common in publicly traded company structures, and that pure holding companies both issue and “in almost every case” repay debt.