Browning v. Comm'r
United States Tax Court
In December 1995, P, the principal shareholder, president, and CEO of SBE, a Vermont-based manufacturing corporation, on the advice of its promoters and his own tax adviser, entered into an offshore employee leasing (OEL) arrangement whereby he agreed to lease his services to T, an Irish corporation that subleased his services to L, a U.S. employee leasing company that subleased his services back to SBE.
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In December 1995, P, the principal shareholder, president, and CEO of SBE, a Vermont-based manufacturing corporation, on the advice of its promoters and his own tax adviser, entered into an offshore employee leasing (OEL) arrangement whereby he agreed to lease his services to T, an Irish corporation that subleased his services to L, a U.S. employee leasing company that subleased his services back to SBE. During the audit years (1995-2000), in consideration of P's services, SBE paid L annual amounts equivalent to what SBE had paid P as wages in prior years. L paid a portion of those amounts to…
1Opinion of the Court
PERRY W. BROWNING, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Browning v. Comm'r
Docket No. 3531-08
United States Tax Court
T.C. Memo 2011-261; 2011 Tax Ct. Memo LEXIS 253; 102 T.C.M. (CCH) 460;
November 3, 2011, Filed
Decision will be entered under Rule 155.
In December 1995, P, the principal shareholder, president, and CEO of SBE, a Vermont-based manufacturing corporation, on the advice of its promoters and his own tax adviser, entered into an offshore employee leasing (OEL) arrangement whereby he agreed to lease his services to T, an Irish corporation that subleased his services…
2Cases cited27 opinions
- Spies v. United StatesSupreme Court of the United States · 1943
- Gajewski v. CommissionerUnited States Tax Court · 1976
- Beaver v. CommissionerUnited States Tax Court · 1970
- Robert W. Bradford v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1986
- Petzoldt v. CommissionerUnited States Tax Court · 1989
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