Amp Incorporated and Consolidated Subsidiaries v. United States

ARCHER, Senior Circuit Judge.

DECISION

AMP Incorporated and Consolidated Subsidiaries (AMP) appeals the summary judgment of the Court of Federal Claims in favor of the United States (the government). See AMP Inc. and Consol. Subsidiaries v. United States, 40 Fed.Cl. 172 (1998) (AMP I). 1 The court held that AMP is not entitled to a redetermination of the foreign tax credit claimed in its 1981 and 1982 tax returns for additional foreign taxes paid by its wholly-owned Brazilian subsidiary. Because AMP is entitled to a foreign tax credit redetermination for such additional payments, we reverse.

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