Gulf-Puerto Rico Lines, Inc. v. Commissioner
United States Tax Court
Petitioner, a foreign corporation, paid taxes to the Commonwealth of Puerto Rico on gross income from all sources whatever. Under sec. 882 its United States source income was taxable in the United States and it was entitled to deductions connected with that United States income including foreign taxes paid with respect thereto. Under Puerto Rico law it was also entitled to a credit against that jurisdiction's taxes for United States taxes paid.
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Petitioner, a foreign corporation, paid taxes to the Commonwealth of Puerto Rico on gross income from all sources whatever. Under sec. 882 its United States source income was taxable in the United States and it was entitled to deductions connected with that United States income including foreign taxes paid with respect thereto. Under Puerto Rico law it was also entitled to a credit against that jurisdiction's taxes for United States taxes paid. During the years in issue petitioner chose to deduct a portion of its Puerto Rico taxes against United States source income rather than increasing its…
1Opinion of the Court
Gulf-Puerto Rico Lines, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Gulf-Puerto Rico Lines, Inc. v. Commissioner
Docket No. 1281-69
United States Tax Court
61 T.C. 644; 1974 U.S. Tax Ct. LEXIS 153;
February 11, 1974, Filed
Decision will be entered under Rule 155.
Petitioner, a foreign corporation, paid taxes to the Commonwealth of Puerto Rico on gross income from all sources whatever. Under sec. 882 its United States source income was taxable in the United States and it was entitled to deductions connected with that United States income including foreign taxes paid with respect…
2Cases cited3 opinions
- Corporacion De Ventas De Salitre Y Yoda De Chile v. CommissionerCourt of Appeals for the Second Circuit · 1942
- Corporacion de Ventas de Salitre y Yoda v. CommissionerUnited States Board of Tax Appeals · 1941
- Gulf-Puerto Rico Lines, Inc. v. CommissionerUnited States Tax Court · 1974