On January 8, 2020, the Tax Court issued its opinion in Adams Challenge UK Limited v. Commissioner, 154 T.C. No. 3. The issue presented in Adams Challenge UK Limited v. Commissioner was whether a United Kingdom private limited liability company, whose vessel was leased to a U.S. company operating on portions of the U.S. Outer Continental Shelf (OCS) received income effectively connected with a U.S. trade or business pursuant to IRC § 882(a)(1), thereby giving rise