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
Business Related Issues
Duty of Consistency

New Capital Fire Inc. v. Commissioner
T.C. Memo. 2021-67

On June 2, 2021, the Tax Court issued a Memorandum Opinion in the case of New Capital Fire Inc. v. Commissioner (T.C. Memo. 2021-67). The primary issue presented in New Capital Fire Inc. v. Commissioner was whether the petitioner is barred under the doctrine of equitable estoppel from changing its reporting of its bases in certain assets that the petitioner acquired in the merger because the statute of limitations bars assessment. Dancing the Merger Two Step

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Scott St. Amand June 21, 2021
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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

New Capital Fire Inc. v. Commissioner
T.C. Memo. 2021-67

On June 2, 2021, the Tax Court issued a Memorandum Opinion in the case of New Capital Fire Inc. v. Commissioner (T.C. Memo. 2021-67). The primary issue presented in New Capital Fire Inc. v. Commissioner was whether the petitioner is barred under the doctrine of equitable estoppel from changing its reporting

Read More »
Scott St. Amand June 21, 2021