Distributive share of foreign partnership income held subpart F income.

• Author: Josephs, Stuart R.
• Position: Brief Article

The Tax Court had previously ruled in Brown Group, 102 TC 616 (1994), that the distributive share of a foreign partnership's income allocated to a controlled foreign corporation was not subpart F income. (See Tax Clinic, "Distributive Share of Foreign Partnership Income Held Not Subpart F Income," TTA, Nov. 1994, at 672.) However, that opinion was withdrawn and reassigned for reconsideration.

In a subsequent decision, the Tax Court reversed itself...