American Air Liquide, Inc. v. Commissioner
United States Tax Court
P is the parent of a consolidated group that includes L. P's ultimate parent is L'Air, a French corporation. L'Air pays royalties to P and L under license agreements for intellectual property owned by P and L and used by L'Air outside the United States.
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P is the parent of a consolidated group that includes L. P's ultimate parent is L'Air, a French corporation. L'Air pays royalties to P and L under license agreements for intellectual property owned by P and L and used by L'Air outside the United States. P treated the royalty income as sec. 904(d)(1)(I), I.R.C., general limitation income, relying on the "reserved" paragraph in sec. 1.904-5(i)(3), Income Tax Regs.; Article 24(3) of the U.S.-France Treaty, the capital nondiscrimination provision; and written statements of Treasury officials. R determined the royalty income is sec. 904(d)(1)(A),…
1Opinion of the Court
AMERICAN AIR LIQUIDE, INC. AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
American Air Liquide, Inc. v. Commissioner
No. 20381-98
United States Tax Court
116 T.C. 23; 2001 U.S. Tax Ct. LEXIS 3; 116 T.C. No. 3; 2001-1 U.S. Tax Cas. (CCH) P54,208; 58 U.S.P.Q.2D (BNA) 1252;
January 16, 2001, Filed
An appropriate order will be entered granting respondent's motion for summary judgment and denying petitioner's motion for summary judgment. Decision will be entered for respondent.
P is the parent of a consolidated group that includes L.
P's ultimate parent is L'Air, a French…
2Cases cited20 opinions
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Naftel v. CommissionerUnited States Tax Court · 1985
- Florida Peach Corp. v. CommissionerUnited States Tax Court · 1988
- Whitney v. RobertsonSupreme Court of the United States · 1888
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