International Tax Blog

Chart of Central de Gas de Chihuahua

Below is a chart of Central de Gas de Chihuahua v. Commissioner, 102 T.C. 515 (1994). The Tax Court held that the Code §482 adjustment made by the IRS was appropriate where one Mexican corporation, Central Gas, allowed a related Mexican corporation the rent-free use of tractors which were used in the U.S. The Code §482 adjustment created deemed rental payments to Central Gas which were U.S. source income. The chart can be viewed as... Read more →

I.R.S. Rules that Mexican Fideicomiso is Not a Trust

Update: June 7, 2013 - See IRS issues Rev. Rul. on Fideicomisos Yesterday the I.R.S. released PLR 201245003, which concluded that a Mexican fideicomiso (or Mexican Land Trust) was not a trust for U.S. tax purposes. If a Mexican fideicomiso is not a trust, then it is not a foreign trust and no Form 3520 or 3520-A would need to be filed. In the ruling, a U.S. corporation (“X”) was formed that was owned by... Read more →

USD School of Law - Procopio International Tax Institute

Yesterday and today I attended the University of San Diego School of Law - Procopio International Tax Institute in beautiful San Diego. Although this was the first time that I attended, it was the eighth annual USD / Procopio conference. I was very impressed with quality of the speakers. The speakers included high level U.S. government tax officials and high level Mexican government tax officials. The private practice speakers were also top knotch. Some of... Read more →