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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