Adams Challenge (UK) Limited v. Commissioner

154 T.C. No. 3

UNITED STATES TAX COURT ADAMS CHALLENGE (UK) LIMITED, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4816-15. Filed January 8, 2020. P is a U.K. private limited liability company whose sole income-producing asset for the years at issue was a multi-purpose support vessel. The vessel was chartered by a U.S. company to assist in decommissioning oil and gas wells and removing debris on portions of the U.S. Outer Continental Shelf (OCS) in the Gulf of Mexico. During 2009-2011 petitioner derived gross income of $45 million from the charter. Foreign corporations…