Tax Coda

Tax Coda

Court vacates Tax Court ruling on loyalty program income in Hyatt case

Hyatt Hotels Corp. v. Commissioner. United States Court of Appeals for the Seventh circuit. No. 24-3239.

Adam Parr's avatar
Adam Parr
Apr 28, 2026
∙ Paid

If legal restrictions or repayment obligations limit control, funds in a centralized loyalty program are not automatically considered income for the operator.

Holding

The Seventh Circuit sent the case …

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