Friday, May 25, 2012

Tax Court Ruled that Permanent Resident's Wages Paid by German Government Not Tax Exempt

The wages of a permanent resident of the United States that were paid by Germany and a foreign government office were not exempt from taxation under the tax code and a North Atlantic Treaty agreement, the U.S. Tax Court held May 1 (Harrison v.Commissioner, T.C., No. 15074-10, 138 T.C. No. 17, 5/1/12).

The Tax Court concluded that Rosemary Harrison was not exempt under Internal Revenue Code Section 893(a) and was not a part of the civilian component within the meaning of the Agreement Between the Parties to the North Atlantic Treaty Regarding the Status of Their Forces (NATO SOFA).

The place where Harrison was employed, the German Defense Administration, is a miscellaneous foreign government office as classified by the U.S. Department of State in its listing of German missions. The entity is not part of and does not carry out diplomatic or consular operations.

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