The company has 90 days to file a notice of appeal to the U.S. Court of Appeals for the Eleventh Circuit
The U.S. Tax Court today completed the next step in the legal process by entering a decision in the ongoing tax case between The Coca-Cola Company and the U.S. Internal Revenue Service. The decision reflects a liability of approximately $2.7 billion. With applicable interest, the total amount is anticipated to be approximately $6.0 billion.
Coca-Cola strongly believes the IRS and the Tax Court misinterpreted and misapplied the applicable regulations involved in the case and will vigorously defend its position on appeal. The company has 90 days to file a notice of appeal to the U.S. Court of Appeals for the Eleventh Circuit. The company looks forward to the opportunity to begin the appellate process and, as part of that process, will pay the agreed-upon liability and interest to the IRS.
On Sept. 17, 2015, the company received a notice from the IRS seeking approximately $3.3 billion of additional federal income tax for years 2007 through 2009. In the notice, the IRS stated its intent to reallocate over $9 billion of income to the U.S. parent company from certain of its foreign affiliates retroactively, rejecting a previously agreed-upon methodology without prior notice to the company.
On Oct. 15, 2015, the IRS designated this matter for litigation, precluding the company from any, and all, alternative means of resolution other than going to court. On November 18, 2020, the Tax Court issued an opinion in which it predominantly sided with the IRS. On Nov. 8, 2023, the Tax Court issued a second related opinion also siding with the IRS on the remaining issue.