Elec. Arts, Inc. v. Comm'r
United States Tax Court
Before the years in issue, petitioner parent (EA) had relied on unrelated video games manufacturers in Taiwan and Japan to manufacture the video games that EA sold. EA created a subsidiary (EAPR) to move the video game manufacturing operations to Puerto Rico. EAPR entered into agreements with an unrelated company (PPI), which was located in Puerto Rico. PPI manufactured ignition modules and related products for small engines.
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Before the years in issue, petitioner parent (EA) had relied on unrelated video games manufacturers in Taiwan and Japan to manufacture the video games that EA sold. EA created a subsidiary (EAPR) to move the video game manufacturing operations to Puerto Rico. EAPR entered into agreements with an unrelated company (PPI), which was located in Puerto Rico. PPI manufactured ignition modules and related products for small engines. PPI did not own equipment, raw materials, or components to manufacture video games. Under the EAPR-PPI agreements, EAPR leased space in PPI's factory, leased employees…
1Opinion of the Court
ELECTRONIC ARTS, INC. AND SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent ELECTRONIC ARTS PUERTO RICO, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Elec. Arts, Inc. v. Comm'r
No. 2433-99; No. 2434-99
United States Tax Court
118 T.C. 226; 2002 U.S. Tax Ct. LEXIS 13; 118 T.C. No. 13;
March 22, 2002, Filed
Petitioners' motion for partial summary judgment granted in part and denied in part.
Before the years in issue, petitioner parent (EA) had
relied on unrelated video games manufacturers in Taiwan and
Japan to manufacture the video games that EA sold. EA…
2Cases cited53 opinions
- Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
- Adickes v. S. H. Kress & Co.Supreme Court of the United States · 1970
- Toyota Motor Manufacturing, Kentucky, Inc. v. WilliamsSupreme Court of the United States · 2002
- United States v. ButlerSupreme Court of the United States · 1936
- Associated Press v. United StatesSupreme Court of the United States · 1945
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