The U.S. Tax Court rejects taxpayers’ use of a foreign sales corporation (FSC) to avoid the Roth IRA contribution limit. In a reviewed opinion, the Tax Court found that the substance over form doctrine applied to a transaction involving Roth IRAs holding stock in an FSC. The court concluded that the taxpayers, not their Roth IRAs, were the owners of the FSC stock. In substance, the FSC dividends were income to the taxpayers, who then contributed the dividends to their Roth IRAs, exceeding the contribution limits. (150 TC No. 7)
