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.
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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
OPINION
RUWE, Judge:*
Respondent determined deficiencies in petitioners’ 1980 and 1981 Federal income taxes in the amounts of $24,180.06 and $18,976.10, respectively. The sole issue for decision is whether the salary and emoluments paid to petitioner,1 Arthur Amaral, by the North Atlantic Treaty Organization in consideration for the performance of services are exempt from taxation by the United States.
The facts have been fully stipulated. The stipulation of facts and attached exhibits are incorporated herein by this reference.
The issue in this case arises out of various international agreements…
2Cases cited11 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
6 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Tate & Lyle, Inc. v. CommissionerUnited States Tax Court · 1994
- Sang J. Park v. CommissionerUnited States Tax Court · 2011
- Bhutta v. Comm'rUnited States Tax Court · 2015
- Amaral v. CommissionerUnited States Tax Court · 1988
- Evgeny Kiselev v. CommissionerUnited States Tax Court · 2018
2 more not listed; retrieve them via the Exa API.