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…

On March 28, the US Tax Court issued its opinion in Good Fortune Shipping, S.A. v. Commissioner, 148 T.C. No. 10, upholding the validity of the “bearer share” regulations under section 883 of the Internal Revenue Code. Good Fortune filed a notice of appeal to the U.S. Court of Appeals for the D.C. Circuit on June 19….