IRS Strongly Disagrees with Tax Court Ruling in Container Corp. Foreign Income Case, Weighs Next Steps

The Internal Revenue Service strongly disagrees with the U.S. Tax Court’s recent ruling in Container Corp. v. Commissioner that guaranty fees paid by a U.S. subsidiary to…

Guaranty Fee Payments by U.S. Subsidiary to Mexican Corporation Analogous to Payments for Service, Tax Court Says

The U.S. Tax Court ruled in a Feb. 17 opinion that guaranty fees paid by a U.S. subsidiary to a Mexican corporation are analogous to payments for a service and are not…