STATEMENT OF EILEEN J. O'CONNOR, ASSISTANT ATTORNEY GENERAL FOR THE JUSTICE DEPARTMENT'S TAX DIVISION, ON THE DECISION OF THE SECOND CIRCUIT COURT OF APPEALS IN TIFD III-E INC. & CASTLE HARBOUR LLC V. U.S.

WASHINGTON, D.C. - “Today’s decision by the United States Court of Appeals for the Second Circuit confirms that illusory allocations of income to foreign or other tax-neutral entities do not shift taxable income away from the entity that earned it. This decision is another paving stone in the Department’s path to stopping abusive tax shelters and restoring integrity to the federal tax laws.”