Ya Global Investments, et al v. Commissioner of Internal Revenue
Case Number:
25-1766
Court:
Nature of Suit:
Companies
Sectors & Industries:
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January 13, 2026
IRS Asks 3rd Circ. To Uphold $100M Bill Against Hedge Fund
The Internal Revenue Service urged the Third Circuit to uphold a $100 million tax bill against a Cayman Islands hedge fund, arguing that the fund's U.S.-based investment manager carried out a domestic business beyond merely securing capital.
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September 19, 2025
Cayman Hedge Fund Takes $100M Tax Dispute To 3rd Circ.
A Cayman Islands hedge fund urged the Third Circuit to revive its challenge to a $100 million tax bill for earning money in connection with a U.S. business, saying the business did not exist, contrary to claims by the IRS and the U.S. Tax Court.