Legal Opinion
Good Fortune Shipping SA v. Comm'r of Internal Revenue
Court of Appeals for the D.C. Circuit
Decided July 27, 2018No. 17-1160PublishedCited by 19 opinions
1Opinion of the Court
Griffith, Circuit Judge:
In 2007, the foreign shipping corporation Good Fortune Shipping SA ("Good Fortune") attempted to exempt some of its U.S.-based income from taxation. But in order to qualify for the exemption, a certain percentage of Good Fortune's stock needed to be owned by residents of a country that provided a reciprocal tax exemption. At that time, the Internal Revenue Service (IRS) categorically prohibited any consideration of bearer shares-securities owned by whoever holds physical certificates issued by the company-when assessing whether a sufficient amount of a foreign…
2Cases cited20 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Federal Communications Commission v. Fox Television Stations, Inc.Supreme Court of the United States · 2009
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- Household Credit Services, Inc. v. PfennigSupreme Court of the United States · 2004
- Village of Barrington v. Surface Transportation BoardCourt of Appeals for the D.C. Circuit · 2011
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3Cited by19 opinions
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