IRS Loses Foreign Tax Treatment Case In DC Circ.

Law360 (July 27, 2018, 7:28 PM EDT) -- The Internal Revenue Service lost a fight in the D.C. Circuit on Friday when the court ruled that it unreasonably interpreted tax law to prevent Marshall Islands-based Good Fortune Shipping from proving it was entitled to a tax break based on its ownership.

Good Fortune sought to exclude its U.S.-source gross transportation income in 2007 under Internal Revenue Code Section 883, which provides an exemption for companies with more than 50 percent ownership by residents of countries whose tax laws grant U.S. companies reciprocity, according to court documents.

However, the IRS in 2003 had issued a regulation excluding companies whose stock...

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