SIH Partners LLLP, Explorer Corporation, Petitioner v. Commissioner of Internal Revenue

19-435

January 13, 2020
Justices Won't Review Tax On $377M Deemed Foreign Income

The U.S. Supreme Court declined Monday to consider a Third Circuit decision upholding taxes on $377 million in foreign income a commodities trader's affiliate was deemed to have received from loans guaranteed by foreign partners.
December 18, 2019
Ruling In $377M Foreign Income Suit Creates Split, Justices Told

A Third Circuit decision upholding taxes on $377 million in income a commodities trader affiliate received from loans guaranteed by foreign partners conflicts with holdings in other circuits and should be overturned, the affiliate has told the U.S. Supreme Court.
December 03, 2019
IRS Asks Justices To Skip $377M Foreign Income Dispute

A commodities trader affiliate owes tax on $377 million stemming from loans guaranteed by its foreign partners, and the U.S. Supreme Court should not upset a Third Circuit decision upholding the tax bill, the U.S. has told the high court.
October 03, 2019
Justices Asked To Hear $377M Tax Suit Over Foreign Income

A commodities trader affiliate has urged the U.S. Supreme Court to hear its $377 million dispute over decades-old tax regulations and resolve a split on whether the Internal Revenue Service must follow its own revenue rulings.

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