International Issues
Apportionment of Interest

Aptargroup Inc. v. Commissioner
158 T.C. No. 4

On March 16, 2022, the Tax Court issued the full opinion in Aptargroup Inc. v. Commissioner (158 T.C. No. 4). The primary issue presented in Aptargroup Inc. v. Commissioner was whether the taxpayer was required to characterize stock in controlled foreign corporation using gross income method. Held: Yes, indeed it was. Aptargroup Inc. v. Commissioner in a Nutshell Aptargroup Inc. owns stock in a controlled foreign corporation (CFC). The CFC apportioned interest expenses under the

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Scott St. Amand June 10, 2022
Procedural Issues
Burden of Proof

Flume v. Commissioner (T.C. Memo. 2020-80)

On June 9, 2020, the Tax Court issued a Memorandum Opinion in the case of Flume v. Commissioner (T.C. Memo. 2020-80). The primary issue before the court in Flume v. Commissioner was whether the petitioners had subpart F income. Burden of Proof in Unreported Income Cases as in Flume v. Commissioner Generally, the IRS’s determinations regarding income set forth in a notice of deficiency are presumed correct and the taxpayer bears the burden of proving

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Scott St. Amand June 9, 2020
International Issues
Controlled Foreign Corporation (CFC)

Whirlpool Financial Corporation v. Commissioner
154 T.C. No. 9

On May 5, 2020, the Tax Court issued its opinion in Whirlpool Financial Corporation v. Commissioner (154 T.C. No. 9). The issue presented in Whirlpool Financial Corporation v. Commissioner was whether the income earned by the petitioner’s Luxembourg controlled foreign corporation (CFC) from sales of appliances to the petitioner and the petitioner’s Mexican CFC constituted foreign base company sales income (FBCSI) under IRC § 954(d) and, as such, was taxable to the petitioner as subpart F

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Scott St. Amand May 5, 2020
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Aptargroup Inc. v. Commissioner
158 T.C. No. 4

On March 16, 2022, the Tax Court issued the full opinion in Aptargroup Inc. v. Commissioner (158 T.C. No. 4). The primary issue presented in Aptargroup Inc. v. Commissioner was whether the taxpayer was required to characterize stock in controlled foreign corporation using gross income method. Held: Yes, indeed it

Read More »
Scott St. Amand June 10, 2022

Flume v. Commissioner (T.C. Memo. 2020-80)

On June 9, 2020, the Tax Court issued a Memorandum Opinion in the case of Flume v. Commissioner (T.C. Memo. 2020-80). The primary issue before the court in Flume v. Commissioner was whether the petitioners had subpart F income. Burden of Proof in Unreported Income Cases as in Flume v.

Read More »
Scott St. Amand June 9, 2020

Whirlpool Financial Corporation v. Commissioner
154 T.C. No. 9

On May 5, 2020, the Tax Court issued its opinion in Whirlpool Financial Corporation v. Commissioner (154 T.C. No. 9). The issue presented in Whirlpool Financial Corporation v. Commissioner was whether the income earned by the petitioner’s Luxembourg controlled foreign corporation (CFC) from sales of appliances to the petitioner and the

Read More »
Scott St. Amand May 5, 2020