Grecian Magnesite Mining v. Cmsnr. IRS
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June 11, 2019
No Tax On $4M Gain For Greek Mining Co., DC Circ. Affirms
The Internal Revenue Service again lost arguments to tax $4 million that a Greek mining company accrued after redeeming a U.S. partnership interest when the D.C. Circuit ruled Tuesday that the sale did not result in U.S.-sourced income.
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October 09, 2018
Greek Mining Co. Owes Tax For $4M Spinoff, DC Circ. Hears
A U.S. tax judge improperly applied a Treasury regulation when he ruled that a Greek mining company did not owe U.S. taxes on roughly $4 million in gains from its sale of holdings in a Pennsylvania-based magnesite producer and distributor, the Internal Revenue Service said Tuesday before a D.C. Circuit panel.
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August 06, 2018
IRS Says Exemption For Greek Mining Co. Sale 'Defies Logic'
A Greek company's claim that its $4 million sale of interest in an American company was foreign-sourced "defies logic," the Internal Revenue Service told the D.C. Circuit Monday.
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July 03, 2018
Greek Mining Co. Says Sale Of US Co. Interest Not Taxable
A Greek mining company told the D.C. Circuit Tuesday the U.S. Tax Court correctly determined its sale of $4 million of interest in a Pennsylvania-based magnesite company was not taxable because the mining company's actions were conducted solely through its home offices abroad, so the income was foreign-sourced.
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June 08, 2018
IRS Accuses Tax Court Of Ignoring Economic Substance
The U.S. Tax Court ignored economic substance and legislative intent in a ruling that overturned a long-standing Internal Revenue Service position that sales of a U.S. trade or business by a foreign partner are taxable, according to an appeal the agency filed with the D.C. Circuit Friday.