No Supreme Court Review of $75 Million Tax After Loan Guarantees

The Supreme Court decided not to hear a partnership’s legal challenge to Treasury regulations and more than $75 million in taxes.

In its Supreme Court petition, SIH Partners LLLP challenged not just the regulations but also the IRS’s decision not to apply the lower 15% tax rate for dividends or perform a further analysis under a revenue ruling. The high court denied the petition in a Jan. 13 order.

The $75 million was part of an IRS tax bill of about $380 million on the partnership, an affiliate of Susquehanna International Holdings Inc., after its two controlled foreign ...