Amaral v. Commissioner
United States Tax Court
Member States of NATO entered into the Ottawa agreement to extend certain privileges and immunities to members of NATO's international staff. Art. 19 of the Ottawa agreement provided for tax exemption for the salaries paid by NATO to its employees on the international staff. The second sentence of art. 19 allowed member States to conclude an arrangement with NATO whereby the member State would hire its nationals and assign them to NATO's international staff.
Read the full summary
Member States of NATO entered into the Ottawa agreement to extend certain privileges and immunities to members of NATO's international staff. Art. 19 of the Ottawa agreement provided for tax exemption for the salaries paid by NATO to its employees on the international staff. The second sentence of art. 19 allowed member States to conclude an arrangement with NATO whereby the member State would hire its nationals and assign them to NATO's international staff. Under art. 19, a member State could tax the amounts which it paid to its nationals pursuant to such an arrangement. The United States…
1Opinion of the Court
Arthur A. Amaral and Lucette M. Amaral, Petitioners v. Commissioner of Internal Revenue, Respondent
Amaral v. Commissioner
Docket No. 9947-85
United States Tax Court
90 T.C. 802; 1988 U.S. Tax Ct. LEXIS 53; 90 T.C. No. 53;
April 26, 1988; As amended May 4, 1988 April 26, 1988, Filed
Decision will be entered under Rule 155.
Member States of NATO entered into the Ottawa agreement to extend certain privileges and immunities to members of NATO's international staff. Art. 19 of the Ottawa agreement provided for tax exemption for the salaries paid by NATO to its employees on the international staff. The…
2Cases cited12 opinions
- Sumitomo Shoji America, Inc. v. AvaglianoSupreme Court of the United States · 1982
- The Chinese Exclusion CaseSupreme Court of the United States · 1889
- Kolovrat v. OregonSupreme Court of the United States · 1961
- Geofroy v. RiggsSupreme Court of the United States · 1890
- Trans World Airlines, Inc. v. Franklin Mint Corp.Supreme Court of the United States · 1984
7 more not listed; retrieve them via the Exa API.