Legal Opinion
PNC Financial Services Group, Inc. v. Commissioner of Internal Revenue Service
Court of Appeals for the D.C. Circuit
Decided August 24, 2007No. 06-1034PublishedCited by 25 opinions
1Opinion of the Court
Opinion for the Court filed by Circuit Judge BROWN.
Dissenting opinion filed by Circuit Judge GRIFFITH.
BROWN, Circuit Judge:
In prior litigation, PNC Financial successfully claimed a foreign tax credit for taxes paid on its behalf in Brazil. That credit, the Internal Revenue Service argues, must be reduced by the amount of an indirect subsidy PNC received from the Brazilian government. The Tax Court agreed, and we now affirm.
I
In an international tax case as complicated, economically and litigiously, as this one, we do well to start with the basics.' When a U.S. bank makes a loan abroad, the…
2Cases cited19 opinions
- Christianson v. Colt Industries Operating Corp.Supreme Court of the United States · 1988
- Arizona v. CaliforniaSupreme Court of the United States · 1983
- Banco Nacional De Cuba v. SabbatinoSupreme Court of the United States · 1964
- Messenger v. AndersonSupreme Court of the United States · 1912
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
14 more not listed; retrieve them via the Exa API.
3Cited by25 opinions
- Margolis v. U-Haul International, Inc.District Court, District of Columbia · 2011
- Hines v. United StatesDistrict Court, District of Columbia · 2009
- Duberry v. Dist. of ColumbiaCourt of Appeals for the D.C. Circuit · 2019
- Dialysis Clinic, Inc. v. LeavittDistrict Court, District of Columbia · 2007
- Jones v. BernankeDistrict Court, District of Columbia · 2008
20 more not listed; retrieve them via the Exa API.