The Second Circuit Court of Appeals held that the Tax Court had no basis for applying the substance-over-form doctrine to payments made to or by domestic international sales corporations (DISCs). Payments from a manufacturing company to the DISC were commissions. Further, the dividends the DISC paid to its Roth IRA shareholders were not excess contributions. […]
The post Second Circuit Also Reverses Tax Court’s Use of Substance-Over-Form for DISC Payments (Benenson, Jr., CA-2) appeared first on Tax & Accounting Blog.