Revenue Ruling 94-16
Internal Revenue Service
1994-1 C.B. 19 (1994)
- Written by Daniel Clark, JD
Facts
The Internal Revenue Service (IRS) sought to clarify the circumstances under which businesses run by Native American—or Indian, to use the IRS’s terminology—tribes faced income taxation under the Internal Revenue Code (code). The IRS described three hypothetical arrangements, all of which envisioned a federally recognized tribe conducting a commercial business. In the first arrangement, the tribe itself operated the business. In the second arrangement, the tribe incorporated itself under the Indian Reorganization Act of 1934 and operated the business as this corporation. In the third arrangement, the tribe formed a corporation under state law; the corporation operated the business, and the tribe was the corporation’s sole shareholder. The IRS issued a revenue ruling detailing the IRS’s position as to how tax law applied to the different arrangements.
Rule of Law
Issue
Holding and Reasoning ()
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