KPMG: Ninth Circuit: FSC used to transfer funds from family business into Roth IRAs (Tax Court reversed) (June 2, 2021)

KPMG has made available for download their article, “Ninth Circuit: FSC used to transfer funds from family business into Roth IRAs (Tax Court reversed)”, which contains the opinion of the U.S. Court of Appeals for the Ninth Circuit in the case of Mazzei v. Commissioner, No. 18-72451 (9th Cir. June 2, 2021). The abstract is as follows:

The U.S. Court of Appeals for the Ninth Circuit today reversed a “reviewed decision” of the U.S. Tax Court that had applied substance-over-form principles in determining who owned a foreign sales corporation (FSC) that was used to transfer funds from a family business into Roth IRAs.

The Ninth Circuit found that the Tax Court—which had set aside the Roth IRAs’ formal ownership of the FSC’s shares—erred in applying the substance-over-form principles.

To see the full article, click: “Ninth Circuit: FSC used to transfer funds from family business into Roth IRAs (Tax Court reversed)”

To download the full opinion, click “Ninth Circuit: FSC used to transfer funds from family business into Roth IRAs (Tax Court reversed)” (June 2, 2021)

Posted by Marin Larkin, Associate Editor, Wealth Strategies Journal.

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