3rd Circ. Upholds Tax Regs In $377M Foreign Income Suit

Law360 (May 7, 2019, 9:08 PM EDT) -- The Third Circuit on Tuesday upheld decades-old tax regulations tied to a $377 million dispute involving the affiliate of a commodities trader, ruling that the IRS wasn't expected to foresee every possible impact of the rules when they were written.

The James A. Byrne United States Courthouse in Philadelphia. A Third Circuit panel Tuesday upheld a U.S. Tax Court ruling based on regulations that say U.S. shareholders must include income from controlled foreign corporations when the foreign units invest in U.S. property. (AP) In a precedential ruling, a three-judge panel affirmed a U.S. Tax Court decision from January 2018 that ruled SIH...

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