Legal Opinion
Danbury, Inc. v. Olive
District Court, Virgin Islands
Decided January 24, 1986No. Civ. No. 1985/269PublishedCited by 13 opinions
1Opinion of the Court
MEMORANDUM OPINION
We are presented here with the prospect of the ultimate tax shelter. Can a United States corporation headquartered in the Virgin Islands avoid paying income tax to both governments? Under the facts of this case, we hold that, by the use of a loophole in the taxing statutes, it can.
I. INTRODUCTION
Before discussing the specifics of this case, an initial introduction is needed to provide an understanding of the Court’s approach to interpretation of tax statutes, as well as a further understanding of the relationship of the United States Internal Revenue Code to the Virgin…
2Cases cited11 opinions
- Ernst & Ernst v. HochfelderSupreme Court of the United States · 1976
- Gould v. GouldSupreme Court of the United States · 1917
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Commonwealth Edison Co. v. MontanaSupreme Court of the United States · 1981
- White v. United StatesSupreme Court of the United States · 1938
6 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Danbury, Inc. v. Anthony Olive, Director, Bureau of Internal Revenue, Government of the Virgin IslandsCourt of Appeals for the Third Circuit · 1987
- Condor Int'l v. CommissionerUnited States Tax Court · 1992
- Bizcap, Inc. v. OliveCourt of Appeals for the Third Circuit · 1989
- Government of the Virgin Islands v. LansdaleDistrict Court, Virgin Islands · 2001
- WIT Equipment Co. v. Director, Virgin Islands Bureau of Internal RevenueDistrict Court, Virgin Islands · 2001
8 more not listed; retrieve them via the Exa API.