The U.S. Tax Court limited the deductions that Sysco Corp. can take on repatriated income, holding Monday that the food services giant failed to distinguish its case from Varian Medical Systems Inc.'s failed bid for identical deductions in an earlier ruling.
The decision restricts Sysco's ability to claim deductions tied to bringing foreign earnings back to the United States. The court's reasoning centered on the company's inability to differentiate its fact pattern from the Varian case, which had previously denied the same type of tax benefit.
Varian Medical Systems had sought similar deductions in an earlier Tax Court proceeding and lost. The court applied that precedent directly to Sysco's case, finding no material differences that would warrant a different outcome.
The ruling comes as companies continue to navigate the tax treatment of repatriated income following changes to international tax rules. Sysco had argued its circumstances merited the deductions, but the court found the underlying structure too similar to the Varian arrangement.
Tax disputes over repatriation deductions have increased as multinational corporations bring foreign profits back to the United States. The Tax Court's reliance on the Varian precedent suggests courts will scrutinize whether companies have genuinely distinct fact patterns or are simply replicating strategies that have already been rejected.
Sysco operates one of the largest food distribution networks in the country, serving restaurants and other foodservice operations. The company did not immediately comment on whether it would appeal the Monday ruling.
