Taxation of Seafarers on Vessels Detained by Covid-19

As the International Maritime Organization recognizes the Day of the Seafarer, it is notable that the tax protections offered crew under treaty and domestic law may not apply to those individuals engaged on vessels which are out of service due to the pandemic. Issues concerning whether a vessel that is out of service is engaged…

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World Oceans Day – The Often Unsung Heroes

Today is International Oceans Day and recognition must be given to the efforts of organizations outside the common public view – the International Maritime Organization and the Organization for Economic Cooperation and Development. The efforts of both organizations, their members and staff are to be comended. The #IMO is the global standard-setting authority for the…

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Bearer Share Regulations under Section 883 of the Code Invalidated by the D.C. Circuit in Good Fortune Shipping SA v. Commissioner

On July 27 the District of Columbia Circuit Court of Appeals issued its opinion in Good Fortune Shipping SA v. Commissioner, No. 17-1160, reversing the Tax Court and invalidating the “bearer share” regulations under § 883 of the Internal Revenue Code. Section 883(c)(1) exempts the United States source income from the international operation of ships…

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U.S. Joint Committee on Taxation Publishes Paper on Corporate Integration

In preparation for a Senate hearing on corporate integration, the Staff of the Joint Committee on Taxation has published “Overview of Approaches to Corporate Integration.”  The paper is available. The Joint Committee’s analysis covers what is familiar ground for many, suggesting systems that have been tried and abandoned in some countries and systems still in effect in…

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