Welcome to TaxBlawg, a blog resource from Chamberlain Hrdlicka for news and analysis of current legal issues facing tax practitioners. Although blawg.com identifies nearly 1,400 active “blawgs,” including 20+ blawgs related to taxation and estate planning, the needs of tax professionals have received surprisingly little attention.
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The Third Circuit yesterday issued a harshly worded rebuke to the taxpayer in Merck v. United States, No. 10-2775 (Jun. 20, 2011), affirming the District Court’s decision that the taxpayer’s swap-and-assign transaction was really a disguised loan that gave rise to Subpart F income. (See TaxProfBlog for a link to the opinion.)
Described briefly, the transactions at issue involved a U.S. company that entered into interest rate swap contracts with a foreign bank. The company then assigned its right to receive payments under the swaps to foreign subsidiaries in exchange for ...