OrbitaxUS Tax Court reclassifies loan structure as dividend payments
|Approved Changes|United States
The US Tax Court has held that a complex finance structure was in substance dividend payments taxable under the US tax law (Barnes Group, Inc. and Subsidiaries v. Commissioner of Internal Revenue, T.C. Memo. 2013-109, Docket No. 27211-09, 16 April 2013).
The case involved a US corporation that had a second-tier subsidiary in Singapore. The US corporation entered into a domestic and foreign…
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