DC Circ. Questions Foreign Tax Treatment Of Bearer Shares

Law360, Washington (April 26, 2018, 8:17 PM EDT) -- An international shipping company urged a D.C. Circuit panel Thursday to grant it the chance to prove it is owned predominantly by residents of other countries, despite the fact its stock is issued in hard-to-trace bearer shares.

Marshall Islands-based Good Fortune Shipping SA said in oral arguments that Internal Revenue Service regulations that preclude foreign-based companies from using bearer shares to show they are based outside of the U.S. for tax purposes are unfair, because they don't even give companies the chance to prove more than half of their shareholders are based abroad.

Flott & Co. PC's Stephen Flott did not...

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