Mar 302016
Taxation law is composed of myriads of laws, regulations, rulings and other issuances — it’s overwhelming even to professional practitioners. From time to time, however, the courts are able to cut through extraneous matters and deliver clear guidance not only for taxpayers but also for tax authorities.
One such instance is the recent case decided by the Court of Tax Appeals (CTA) on Jan. 27, 2016. The issue facing the court was whether a domestic corporation that received additional capital by way of contribution from its non-resident shareholder is liable as a donee to pay the alleged donor’s tax on the contribution.