Taisei Fire & Marine Ins. Co. v. Commissioner
United States Tax Court
Ps, Japanese insurance companies, wrote reinsurance through F, a North Carolina corporation, which conducted its operations in the United States. Held, on the facts, F was an "agent of an independent status" within the meaning of Art. 9(5) of the Convention for the Avoidance of Double Taxation, Mar. 8, 1971, U.S.-Japan, 23 U.S.T.
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Ps, Japanese insurance companies, wrote reinsurance through F, a North Carolina corporation, which conducted its operations in the United States. Held, on the facts, F was an "agent of an independent status" within the meaning of Art. 9(5) of the Convention for the Avoidance of Double Taxation, Mar. 8, 1971, U.S.-Japan, 23 U.S.T. (Part 1) 969, and was therefore not a permanent establishment, during the years at issue, of any of petitioners within the meaning of Art. 8(1) of such convention.
1Opinion of the Court
The Taisei Fire and Marine Insurance Co., Ltd., et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Taisei Fire & Marine Ins. Co. v. Commissioner
Docket Nos. 14296-92, 14297-92, 14298-92, 14299-92
United States Tax Court
104 T.C. 535; 1995 U.S. Tax Ct. LEXIS 27; 104 T.C. No. 27;
May 2, 1995, Filed
Decisions will be entered under Rule 155.
Ps, Japanese insurance companies, wrote reinsurance through F, a North Carolina corporation, which conducted its operations in the United States. Held, on the facts, F was an "agent of an independent status" within the meaning of Art. 9(5) of the…
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- Andre Maximov, as Trustee for the Benefit of H. Robbin Fedden U/a Dated 10/24/47 v. United StatesCourt of Appeals for the Second Circuit · 1962
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