Legal Opinion
First Chicago Nbd Corporation v. Commissioner of Internal Revenue
Court of Appeals for the First Circuit
Decided January 28, 1998No. 96-4006PublishedCited by 32 opinions
1Opinion of the Court
POSNER, Chief Judge.
Section 901 of the Internal Revenue Code allows taxpayers to take a credit against their federal income taxes for taxes paid to a foreign government. What if the taxpayer owns just a piece of a foreign corporation? Section 902(a), as it read until 1986, provided that “a domestic corporation which owns at least 10 percent of the voting stock of a foreign corporation from which it receives dividends” shall (for purposes of the foreign tax credit) be deemed to have paid to the foreign government the fraction of foreign taxes on the profits of the foreign corporation that is…
2Cases cited18 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Commissioner v. SchleierSupreme Court of the United States · 1995
- Goodell v. KochSupreme Court of the United States · 1930
- Health Insurance Ass'n of America, Inc. v. ShalalaCourt of Appeals for the D.C. Circuit · 1994
- Kohler Co. v. Moen Incorporated, F/k/a Stanadyne, Inc.Court of Appeals for the Seventh Circuit · 1993
13 more not listed; retrieve them via the Exa API.
3Cited by32 opinions
- Bankers Life and Casualty Company v. United StatesCourt of Appeals for the Seventh Circuit · 1998
- Kornman & Associates, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 2008
- Gloria Cannon v. Kenneth S. Apfel, Commissioner of Social SecurityCourt of Appeals for the Seventh Circuit · 2000
- 330 West Hubbard Restaurant Corporation, Doing Business as Coco Pazzo v. United StatesCourt of Appeals for the Seventh Circuit · 2000
- BUNNEY v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2000
27 more not listed; retrieve them via the Exa API.