Legal Opinion
Framatome Connectors USA, Inc. v. Commissioner
Court of Appeals for the Second Circuit
Decided September 7, 2004No. Docket Nos. 03-40119, 03-40121PublishedCited by 5 opinions
1Opinion of the Court
SUMMARY ORDER
The petitioners, referred to by the parties and in the opinion of the tax court as “Burndy-US,” appeal from a judgment of the tax court concluding that Burndy-Japan, a Japanese corporation in which Burndy-US owned shares, was not a controlled foreign corporation (“CFC”)1 of Burndy-US in 1992. Framatome Connectors US, Inc. v. Comm’r, 118 T.C. 32, 2002 WL 58234 (2002) (“Framatome”). The unique and complex history of the creation and ownership of Burndy-Japan by Burndy-US, Sumitomo Electric Industries, Ltd., and Furukawa Electric Co., Ltd. (collectively, the “Shareholders”), and the…
2Cases cited5 opinions
- Anderson v. City of Bessemer CitySupreme Court of the United States · 1985
- Curley v. AMR Corp.Court of Appeals for the Second Circuit · 1998
- Warren Richard Follum v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1997
- Framatome Connectors USA, Inc. v. Comm'rUnited States Tax Court · 2002
- Riverkeeper, Inc. v. CollinsCourt of Appeals for the Second Circuit · 2004
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- New York Guangdong Fin., Inc. v. Comm'rUnited States Tax Court · 2008