Document Type
Article
Publication Date
5-1-1991
ISSN
2688-6480
Publisher
Tax Analysts
Language
en-US
Abstract
Every day, in ports around the country, thousands of oceangoing vessels and aircraft transport passengers and property to and from the United States. In many instances, the international transportation operation is foreign-owned and has neither filed nor paid any U.S. income taxes, relying upon tax exemptions under U.S. law or bilateral tax conventions. Newly issued Revenue Procedure 91- 12 requires all international transportation operations that transport passengers or property to or from the U.S. to file U.S. tax returns. Whether or not a tax is due, a U.S. tax return must be filed and certain information disclosed. Large penalties may be imposed for failure to file. Furthermore, the IRS substantively defined "U.S.- source gross transportation income" in a fashion that may surprise many international transportation operations. This article examines the U.S. income taxation of international transportation operations in light of Revenue Procedure 91-12.
Recommended Citation
Chi K. Cheung & Kevin Outterson,
Revenue Procedure 91-12: The IRS Launches an Information-Gathering Offensive Against International Transportation Operations
,
91
Tax Notes Today International
71
(1991).
Available at:
https://scholarship.law.bu.edu/faculty_scholarship/1921
