Therefore, it meets the threshold requirement for limited safe haven. Moreover, the provision of medical services appears to fall under the qualifications of the SCM that services be a controlled service transaction or a group of transactions. This provision of services is not one of the prohibited services including manufacturing, production, extraction of mineral resources, construction, reselling, research and development, engineering, financial, or insurance.

In United Parcel Service of America, Inc. v. Commissioner, 254 F.3d 1014 (11th Cir. 2001), the plan seemed designed for the purposes of tax evasion. UPS sought to shift income to a wholly owned subsidiary in Bermuda through the purchase of insurance on excess value charges for parcels with a value greater than $100. UPS distributed shares of the Bermuda subsidiary (OPL) as a taxable dividend to UPS shareholders. UPS then purchased an insurance policy for its customers from National Union, which then entered into a...
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