Daily Tax Update - August 7, 2017: IRS Prevails in ‘Son-of-BOSS’ Tax Court Case

IRS Prevails in ‘Son-of-BOSS’ Tax Court Case:  Today, the US Tax Court issued a memorandum opinion in BCP Trading and Investments, LLC v. Commissioner, holding that a “purported partnership that used almost perfectly offsetting bets on foreign currency to pass over $3.3 billion of tax losses through to its partners” should be disregarded for tax purposes. The Tax Court found that the partnership—in which partners contributed only $16.5 million—“was created to carry out a tax-avoidance scheme . . . and . . . that the client members never intended to run a business through [the partnership].”

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Join members of Steptoe’s tax policy practice on Wednesday, August 16 for a lively discussion about the state of the current legislative and regulatory environment, what that may mean for tax reform, and what your company can be doing now to protect its interests. Click here for more information about our upcoming August Recess Tax Policy Webinar.