General Electric Co. v. United States

This income tax case comes before the court on the parties’ stipulation of facts. General Electric Co. (GE) seeks a refund for taxes and interest paid for its 1966 tax year. The issues presented in this case1 involve interpretation of the regulations promulgated under I.R.C. § 963. We must decide whether plaintiff was correct in applying the special rules of Treas. Reg. § 1.963-4 in determining the amount of its foreign tax credit on distributions received from foreign corporations covered by an election under I.R.C. § 963 and whether it properly attributed a distribution received from a…