Legal Opinion
Vitco, Inc. v. Government of the Virgin Islands and Reuben Wheatley, Commissioner of Finance
Court of Appeals for the Third Circuit
Decided July 26, 1977No. 77-1065PublishedCited by 17 opinions
1Opinion of the Court
OPINION OF THE COURT
WEIS, Circuit Judge
One may argue that the mirror system of taxation is not always the fairest of them all, but it does reflect the congressional intent to implement some degree of uniformity. In this appeal, we conclude that not only must statutory language be transposed but so must authorized implementing regulations as well. Accordingly, we hold that a Virgin Islands corporation must pay its tax obligations on all of its income to the Virgin Islands despite minimal contacts there. In addition, the withholding provisions relating to dividends paid to a mainland…
2Cases cited7 opinions
- Shaffer v. CarterSupreme Court of the United States · 1920
- United States Glue Co. v. Town of Oak CreekSupreme Court of the United States · 1918
- Cream of Wheat Co. v. County of Grand ForksSupreme Court of the United States · 1920
- George H. T. Dudley v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Chicago Bridge and Iron Company, Ltd. v. Ruben B. Wheatley, Commissioner of FinanceCourt of Appeals for the Third Circuit · 1970
2 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Danbury, Inc. v. Anthony Olive, Director, Bureau of Internal Revenue, Government of the Virgin IslandsCourt of Appeals for the Third Circuit · 1987
- Condor Int'l v. CommissionerUnited States Tax Court · 1992
- New England Merchants National Bank v. Iran Power Generation & Transmission Co.District Court, S.D. New York · 1980
- Antonio Gumataotao v. Director of Department of Revenue and TaxationCourt of Appeals for the Ninth Circuit · 2001
- Chase Manhattan Bank, N.A. v. Government of the Virgin Islands, Bureau of Internal RevenueCourt of Appeals for the Third Circuit · 2002
12 more not listed; retrieve them via the Exa API.