Core Viewpoint - The IRS has assessed 4 billion in taxes, penalties, and interest on Yum! Brands due to a tax-deferred reorganization in 2014, leading the company to sue the IRS to prevent collection of these funds [1][9][11]. Company Overview - Yum! Brands is the parent company of KFC, Taco Bell, Pizza Hut, and Habit Burger & Grill, having spun off from PepsiCo in 1997, and is one of the largest restaurant chains globally with over 61,000 locations in 155 countries [2][3]. Tax-Related Developments - Yum! Brands announced a relocation of its headquarters from Louisville, Kentucky to Plano, Texas, primarily due to tax considerations, as Texas has a 0% corporate income tax rate compared to Kentucky's 5% [4]. - The company has a history of tax-related issues, including the current dispute with the IRS regarding a 2014 reorganization [4][10]. 2014 Reorganization Details - In 2014, Yum! Brands underwent a corporate reorganization to focus on brand-based divisions rather than geographic ones, aiming to drive growth [5]. - The reorganization involved issuing stock in exchange for stock in previous subsidiaries, which Yum! Brands believed qualified for tax deferral under Internal Revenue Code Section 368(a)(1)(B) [6][8]. IRS Dispute - The IRS claims Yum! Brands owes 2.1 billion in taxes, 1.5 billion in interest, totaling over 1.9 billion and income tax payment of $414 million [9][10]. - Yum! Brands has contested the IRS's position, asserting that it met all requirements for tax deferral, but has faced unsuccessful appeals in court [10][11].
What To Know About The IRS's $4 Billion Tax Assessment On Yum! Brands