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Tax Court holds foreign parent's fee for guarantying U.S. subsidiary's debt is foreign source service income
- Fox Rothschild LLP
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- USA
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- May 29 2010
In Container Corp, 134 TC No 5 , Tax Ct Rep (CCH) 58131, 2010 WL 571831 (2010), a case of first impression, the Tax Court, per the opinion of Justice Holmes, held that payments received by Vitro, S.A., a Mexican corporation, from its US subsidiary for the guarantee of the subsidiary's debt obligations was not income from sources within the U.S. under Section 861 , and, therefore, was not subject to withholding under Section 1442
Tax Court, in a fully reviewed opinion, holds that 90 stock loan tax scheme program was a disguised sale
- Fox Rothschild LLP
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- USA
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- July 10 2010
In August 2001, Calloway ("Petitioner") entered into an agreement with Derivium Capital, LLC whereby Petitioner transferred 990 shares of his IBM common stock to Derivium in exchange for the sum of $93,586
Reasonable cause to avoid accuracy related penalty based on advice of legal counsel rejected by Tax Court in Canal Corp. and Subsidiaries et al v. Commissioner, 135 T.C. No.9 (2010).
- Fox Rothschild LLP
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- USA
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- February 13 2011
In Canal Corp, supra, the Tax Court recently held that a corporation's 1999 transfer of a wholly owned subsidiary to a joint venture was a disguised sale that required the company to include in capital gain the amount realized in the year of sale on its consolidated federal income tax return
UK telecommunications company Vodafone recently receives favorable ruling from Supreme Court of India
- Fox Rothschild LLP
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- India
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- June 26 2012
This past January, the Supreme Court in India ruled in Vodafone International Holdings B.V v. Union of India,Civil Appeal No. 733 of 2012 (arising from S.L.P. (C) No. 26529 of 2010) that the sale of stock of a company that was non-resident in India to another non-resident company was not subject to income tax in India
