SIH Partners LLLP Explorer Par v. Commissioner of Internal Reven
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June 21, 2019
3rd Circ. Went Too Far In $377M Tax Ruling, Partnership Says
A Third Circuit panel wrongly found that an affiliate of Susquehanna International Group LLP had an additional $377 million in taxable income stemming from a loan guarantee, the affiliate said Friday in requesting a rehearing from a full roster of judges.
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November 14, 2018
3rd Circ. Urged To Back Ruling In $377M Foreign Income Row
The Internal Revenue Service urged the Third Circuit on Wednesday to uphold a U.S. Tax Court decision finding an additional $377 million in taxable income for a U.S. shareholder, saying that loan guarantees from offshore subsidiaries trigger a requirement to include the subsidiaries' earnings.
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September 20, 2018
Tax Court Erred In $377M Foreign Income Row, 3rd Circ. Told
The U.S. Tax Court wrongly upheld unreasonable U.S. Treasury regulations on controlled foreign corporation income, an investment firm told the Third Circuit in a brief filed Wednesday, noting that under the regulations, two of 39 loan guarantors were counted as ensuring the entire loan amount, and it was taxed as income.