Tax Court attributes contract manufacturer's activities to principal

Article Abstract:

The authors discuss the US Tax Court's decision in Suzy's Zoo in regard to the use of contract manufacturers and the generation of foreign income.

Manufacturing industry, Manufacturing industries, Contracts, Foreign source income taxation, Controlled foreign corporations

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Final code sec. 894 regulations: treaty benefits for hybrid entity payments

Article Abstract:

The authors discuss the IRS' final regulations regarding tax treaty benefits for hybrid corporate entities under IRC section 894.

Hybrid instruments (Finance), Hybrid instruments (Securities)

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MedChem (P.R.) Inc.: the confused state of contract manufacturing

Article Abstract:

The authors discuss the US Tax Court's decision in MedChem (P.R.), Inc., in which the court failed to rule on whether contract manufacturing met the 'manufacturing exception' of IRC section 954(d)(1)(A).

Interpretation and construction, Tax law, Tax deductions, Contract manufacturing

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