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