The Coca-Cola Company and Subsidiaries v. Commissioner

149 T.C. No. 21

UNITED STATES TAX COURT THE COCA-COLA COMPANY & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 31183-15. Filed December 14, 2017. P, a U.S. corporation, does business in Mexico through a branch (Licensee). For taxable years 2007-2009 Licensee paid royalties to P for the use of P’s intangible property and claimed deductions for those royalties on its Mexican corporate income tax returns. P reported all of Licensee’s income on its consolidated Federal income tax returns for 2007-2009 and claimed foreign tax credits (FTCs) under I.R.C. sec. 901…