Bhada v. Commissioner
United States Tax Court
Ps were shareholders of M. M was a domestic corporation, and MI was its wholly-owned foreign subsidiary. The boards of directors of M and MI decided to take advantage of the lower income tax rates available in the areas outside the United States in which MI operated by changing the corporate structure so that MI would become the parent corporation and M the subsidiary.
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Ps were shareholders of M. M was a domestic corporation, and MI was its wholly-owned foreign subsidiary. The boards of directors of M and MI decided to take advantage of the lower income tax rates available in the areas outside the United States in which MI operated by changing the corporate structure so that MI would become the parent corporation and M the subsidiary. To effect the change, MI gave 30 million shares of its common stock plus $ 0.35 per share (a total of $ 10,500,000) to the shareholders of M, including Ps, in return for 30 million shares of the common stock of M. After the…
1Opinion of the Court
Rohinton K. Bhada and Patricia A. Bhada, Petitioners v. Commissioner of Internal Revenue, Respondent; Edward J. Caamano and Janice W. Caamano, Petitioners v. Commissioner of Internal Revenue, Respondent
Bhada v. Commissioner
Docket Nos. 22588-86, 22589-86
United States Tax Court
89 T.C. 959; 1987 U.S. Tax Ct. LEXIS 156; 89 T.C. No. 67;
November 5, 1987; As amended November 6, 1987 November 5, 1987, Filed
Ps were shareholders of M. M was a domestic corporation, and MI was its wholly-owned foreign subsidiary. The boards of directors of M and MI decided to take advantage of the lower income tax rates…
2Cases cited19 opinions
- Crooks v. HarrelsonSupreme Court of the United States · 1930
- Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
- Commissioner v. AckerSupreme Court of the United States · 1959
- United States v. CalamaroSupreme Court of the United States · 1957
- Lang v. CommissionerSupreme Court of the United States · 1933
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