Legal Opinion
Northern Indiana Public Service Company v. Commissioner of Internal Revenue, Cross-Appellee
Court of Appeals for the Seventh Circuit
Decided June 6, 1997No. 96-1659, 96-1758PublishedCited by 52 opinions
1Opinion of the Court
BAUER, Circuit Judge.
This appeal from the United States Tax Court requires us to examine whether interest payments on a note made by a domestic corporation to its wholly-owned Netherlands Antilles subsidiary are exempt from United States withholding tax, under the United States-Netherlands Income Tax Convention. The Tax Court determined that the payments fall within the ambit of the Convention and are exempt from United States taxation. We affirm.
BACKGROUND
Northern Indiana Public Service Company (“Taxpayer”) is a domestic public utility company. In 1981, Taxpayer formed a foreign subsidiary…
2Cases cited16 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964
- Louis Buddy Yosha v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1988
11 more not listed; retrieve them via the Exa API.
3Cited by52 opinions
- Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner, in No. 97-7484 v. Commissioner of Internal Revenue Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner v. Commissioner of Internal Revenue, in No. 97-7527Court of Appeals for the Third Circuit · 1998
- Rauenhorst v. Comm'rUnited States Tax Court · 2002
- Rogers v. United StatesCourt of Appeals for the Tenth Circuit · 2002
- Del Commercial Properties, Inc. v. CommissionerCourt of Appeals for the D.C. Circuit · 2001
- TD Banknorth, N.A. v. Department of TaxesSupreme Court of Vermont · 2008
47 more not listed; retrieve them via the Exa API.