Framatome Connectors USA, Inc. v. Comm'r
United States Tax Court
Controlled Foreign Corporation Issue : In 1992, Burndy-US (B-US), a predecessor of Framatome Connectors USA, Inc., one of the petitioners (Ps), owned 50 percent of the stock of Burndy-Japan (B-J). Furukawa Electric Co. (F) and Sumitomo Electrical Indus., Ltd.
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Controlled Foreign Corporation Issue : In 1992, Burndy-US (B-US), a predecessor of Framatome Connectors USA, Inc., one of the petitioners (Ps), owned 50 percent of the stock of Burndy-Japan (B-J). Furukawa Electric Co. (F) and Sumitomo Electrical Indus., Ltd. (S), each owned 25 percent of the stock of B-J. Ps contend that B-US owned more than 50 percent of the voting power of B-J stock and owned more than 50 percent of the value of B-J stock, and that, as a result, B-J was a controlled foreign corporation (CFC) in 1992 under both sec. 957(a)(1) and ( 2), I.R.C. Held: B-J was not a CFC in 1992…
1Opinion of the Court
FRAMATOME CONNECTORS USA, INC., PRESENTLY KNOWN AS FRAMATOME CONNECTORS USA HOLDING INC., AND SUBSIDIARIES, AND BURNDY CORPORATION PRESENTLY KNOWN AS FRAMATOME CONNECTORS USA INC. Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent FRAMATOME CONNECTORS USA, INC., AND SUBSIDIARIES, N.K.A. FRAMATOME CONNECTORS USA HOLDING INC., AND SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Framatome Connectors USA, Inc. v. Comm'r
No. 5030-98; No. 9160-99
United States Tax Court
118 T.C. 32; 2002 U.S. Tax Ct. LEXIS 3; 118 T.C. No. 3;
January 16, 2002., Filed
Petitioners are…
2Cases cited45 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Higgins v. SmithSupreme Court of the United States · 1940
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- United States v. DavisSupreme Court of the United States · 1962
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