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Subsequent Events | 6 Months Ended
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Jun. 30, 2014
Subsequent Events |
Subsequent Events | Note 17—Subsequent Events Norway tax investigations and trial—On July 2, 2014, the Norwegian district court in Oslo acquitted our three subsidiaries, two external tax attorneys and an external tax advisor of all criminal charges related to the disclosures in our Norwegian tax returns for the years 1999 through 2002 and statutory financial statements for the years ended December 31, 1996 through 2001. On July 16, 2014, the Norwegian authorities dropped the financial claim of NOK 1.8 billion, equivalent to approximately $300 million, against two of our subsidiaries, fully closing this matter, and on the same date, filed an appeal with respect to the following charges: (a) disclosures in our Norwegian tax returns related to a dividend payment in 2001, (b) disclosures in our Norwegian tax returns related to an intercompany rig sale in 1999 and (c) certain inaccuracies in Norwegian statutory financial statements for the years ended December 31, 1996 through 2001. We believe our Norwegian tax returns are materially correct as filed, and we intend to continue to vigorously contest any assertions to the contrary by the Norwegian civil and criminal authorities in connection with the various transactions being investigated. An unfavorable outcome on the Norwegian civil or criminal tax matters could result in a material adverse effect on our consolidated statement of financial position, results of operations or cash flows. See Note 6—Income Taxes—Tax returns—Norway tax investigations and trial. Petrobras withholding taxes—In July 2014, we received letters from Petróleo Brasileiro S.A. (“Petrobras”) informing us that the Brazilian Federal Revenue Service (the “RFB”) is conducting a review to determine whether Petrobras correctly withheld income taxes from charter agreement remittances in 2008 and 2009 related to work performed by its contractors, including us. Petrobras indicated that, if it loses its ongoing appeals, it will seek to recover from its contractors, including us, any taxes, penalties, interest and fees that it is required to pay to the RFB as a result of the review. Petrobras has informed us that it has received from the RFB infraction notices related to work performed by us for BRL 283 million, equivalent to approximately $128 million, excluding penalties, interest and fees. We have informed Petrobras that we believe it has no basis for seeking reimbursement from us, and we intend to vigorously contest any assertions to the contrary. An unfavorable outcome on these matters could result in a material adverse effect on our consolidated statement of financial position, results of operations or cash flows. Tax rate—In December 2013, the U.K. Treasury released draft proposals that would cap the amount a U.K.-based contractor would be able to claim as a deductible expense for charter payments made to related companies. A ring fence was also proposed to ensure that the profits from activities in relation to the chartering of rigs from affiliates are not reduced by tax relief from any unconnected activities. On July 17, 2014, the U.K. legislation received Royal Assent with retroactive application effective as of April 2014. As a result, we expect our effective tax rate on our worldwide earnings to increase beginning in the third quarter of 2014. Transocean Partners LLC —On August 5, 2014, we completed an initial public offering to sell a noncontrolling interest in Transocean Partners LLC, a Marshall Islands limited liability company, which was formed on February 6, 2014, by Transocean Partners Holdings Limited, our wholly owned subsidiary, to own, operate and acquire modern, technologically advanced offshore drilling rigs.

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- Definition The entire disclosure for significant events or transactions that occurred after the balance sheet date through the date the financial statements were issued or the date the financial statements were available to be issued. Examples include: the sale of a capital stock issue, purchase of a business, settlement of litigation, catastrophic loss, significant foreign exchange rate changes, loans to insiders or affiliates, and transactions not in the ordinary course of business. + References No definition available. + Details
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