The Tax Court held that a portion of a company's 2017 mandatory repatriation tax inclusion under IRC Section 965 from a CFC with a non-calendar tax year is exempt from tax under IRC Section 245A.However, the Court correspondingly held that a portion of that company's deemed-paid foreign income taxes are not creditable.Taxpayers should evaluate (1) their opportunities to file protective or actual refund claims; and (2) the applicable statute of limitations and other elements of their tax controversy strategy. In Varian Medical Systems, Inc. v. Commissioner, 163 T.C. No 4 (August 26, 2024), the US Tax Court held that a non-calendar...