Cayman Fund Tells 3rd Circ. Error Sinks $100M Tax Ruling

By Anna Scott Farrell · February 25, 2026, 5:36 PM EST

The Internal Revenue Service has been unable to show that a Cayman Islands hedge fund carried out an on-shore business, the fund told the Third Circuit in challenging a U.S. Tax...

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Case Information

Case Title

Ya Global Investments, et al v. Commissioner of Internal Revenue

Case Number

25-1766

Court

Appellate - 3rd Circuit

Nature of Suit

Date Filed

April 28, 2025