General Foods Corp. v. Commissioner

Petitioner, a domestic corporation, received dividends during the taxable years from certain of its wholly owned foreign subsidiaries. The dividends were paid in part from the subsidiary's current profits and in part from the profits of prior years. Held, in computing the foreign tax credit under section 131 (f) of the Revenue Act of 1934, the foreign tax deemed to have been paid by the petitioner should be computed for each separate year on the accumulated profits from which the dividends were paid; held, further, that the limitation upon the credit under the proviso in section 131 (f) is…