The Resource Adams Challenge (UK) Ltd v Commissioner of Internal Revenue : 156 TC No 2

Adams Challenge (UK) Ltd v Commissioner of Internal Revenue : 156 TC No 2

Label
Adams Challenge (UK) Ltd v Commissioner of Internal Revenue : 156 TC No 2
Title
Adams Challenge (UK) Ltd v Commissioner of Internal Revenue : 156 TC No 2
Contributor
Subject
Language
  • eng
  • eng
Summary
Judgment by US States Tax Court, decision date 21 January 2021. This judgment is a follow-up to a previous decision of the Tax Court, reported at (2020) 22 ITLR 390. That judgment held that the taxpayer company, resident in the United Kingdom, which owned and leased out a support vessel to perform work decommissioning oil and gas wells on the US Outer Continental Shelf in the Gulf of Mexico, had received income effectively connected with the conduct of a US trade or business and was not protected from US taxation by the UK-US double taxation convention. The consequence of that earlier decision was that the UK-resident company was liable to US income tax on the profit attributable to its rental activity on the US Outer Continental Shelf
Citation source
In: International tax law reports. - London. - Vol. 23 (2021), part 4 ; p. 709-746
Geographic coverage
North America
Language note
English
http://library.link/vocab/relatedWorkOrContributorName
Baker, P
http://library.link/vocab/subjectName
  • case law
  • tax treaty
  • foreign company
  • tax return
  • non-discrimination
Label
Adams Challenge (UK) Ltd v Commissioner of Internal Revenue : 156 TC No 2
Link
https://library.ibfd.org/custom/web/SD_PDF/scans/2021/G-I/ITLR/vol.23/4_709-746.pdf
Publication
Note
20210511

Library Locations

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      52.3736660 4.9336932
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