White Paper

Tax Court Holds Section 883 Regulations Valid under Chevron Test


U.S. Tax Court issues opinion upholding the validity of regulations issued under Internal Revenue Code Section 883.

The gross income from the international operation of ships by foreign corporations, if the foreign country in which the corporation is organized grants an equivalent exemption to corporations organized in the United States, is exempt from U.S. tax by Code Section 883(c)(1). This code section provides that the exemption doesn’t apply if 50+% of the value of a foreign corporation’s stock is owned those who nonresidents of a foreign country that grants an equivalent exemption to U.S. corporations. In this case the ownership regulations validity was challenged. The Tax Court’s holding in favor of the validity of the Ownership Regulations is specific to the specific provisions at issue in those regulations.



Andrew R. Roberson

McDermott Will & Emery LLP

  • Partner in the law firm of McDermott Will & Emery LLP and is based in the firm’s Chicago office
  • Focuses on tax controversy and litigation matters
  • Has represented clients before the IRS Examination Division and Appeals Office and has been involved in matters at all levels of the federal court system, including the United States Tax Court, several U.S. Courts of Appeal and the Supreme Court
  • Experience settling tax disputes through alternative dispute resolution procedures, including fast track settlement, and representing clients in CAP audits
  • Frequent speaker and writer on tax controversy matters
  • LL.M. degree, New York University School of Law; J.D. degree, Pepperdine University School of Law; B.A. degree, University of Washington
  • Can be contacted at [email protected]

Roger J. Jones

McDermott Will & Emery

Roger J. Jones represents clients in tax controversy and litigation matters at all levels of the federal court system, before the Internal Revenue Service (IRS), and before various state courts and tax agencies. He has represented taxpayers, including numerous Fortune 500 companies, in more than 80 docketed cases before the US Supreme Court, most of the US courts of appeals, federal district courts, the US Court of Federal Claims and the US Tax Court.

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