Legal Opinion
Riggs National Corp. & Subsidiaries v. Commissioner
Court of Appeals for the D.C. Circuit
Decided January 12, 1999No. 98-1039PublishedCited by 26 opinions
1Opinion of the Court
Opinion for the Court filed by Circuit Judge SILBERMAN.
SILBERMAN, Circuit Judge:
Riggs Bank, asserting that it had paid taxes to the Brazilian government with respect to interest income on loans it had made to the Central Bank of Brazil, claimed foreign tax credits under § 901 of the Internal Revenue Code. The Commissioner disallowed the credits on the theory that Riggs was not “legally liable” for the tax under Brazilian law, and the Tax Court denied Riggs’ petition for relief. We reverse.
I
A
Riggs National Corporation’s subsidiary Riggs Bank was one of numerous banks that made loans to the…
2Cases cited14 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Banco Nacional De Cuba v. SabbatinoSupreme Court of the United States · 1964
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Underhill v. HernandezSupreme Court of the United States · 1897
- W. S. Kirkpatrick & Co. v. Environmental Tectonics Corp., InternationalSupreme Court of the United States · 1990
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3Cited by26 opinions
- World Wide Minerals, Ltd. v. Republic of KazakhstanCourt of Appeals for the D.C. Circuit · 2002
- Agudas Chasidei Chabad of United States v. FederationCourt of Appeals for the D.C. Circuit · 2008
- Devincci Hourani v. Alexander MirtchevCourt of Appeals for the D.C. Circuit · 2015
- Doe I v. State of IsraelDistrict Court, District of Columbia · 2005
- Presbyterian Church of Sudan v. Talisman Energy, Inc.District Court, S.D. New York · 2003
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