Judgment by the United States Tax Court, judgment date 18 September 2019. In this case the Court granted motions for summary judgment for the IRS, finding the taxpayers' CFC in Hong Kong was not a domestic corporation or a qualified foreign corporation and thus that the CFC's distribution to the taxpayers was not qualified dividend income but was taxable to the taxpayers at ordinary income rates. The Tax Court also found that the taxpayers had received a constructive dividend from a Cypriot CFC on the cancellation of an account receivable balance owned to that CFC.