The Limited, Inc. v. Comm'r
United States Tax Court
P's subsidiary, D, a domestic corporation, is a credit card bank, issuing private label credit cards to customers of P. F1 is a controlled foreign corporation with respect to P. F2 is a foreign subsidiary of F1. F1 funded F2, which purchased certificates of deposit (CDs) from D. HELD: The CDs are U.S. property within the meaning of sec. 956(b)(1), I.R.C., and not deposits with persons carrying on the banking business within the meaning of sec. 956(b)(2)(A), I.R.C.
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P's subsidiary, D, a domestic corporation, is a credit card bank, issuing private label credit cards to customers of P. F1 is a controlled foreign corporation with respect to P. F2 is a foreign subsidiary of F1. F1 funded F2, which purchased certificates of deposit (CDs) from D. HELD: The CDs are U.S. property within the meaning of sec. 956(b)(1), I.R.C., and not deposits with persons carrying on the banking business within the meaning of sec. 956(b)(2)(A), I.R.C. HELD, FURTHER, the CDs are attributed to F1 pursuant to sec. 1.956-1T(b)(4), Temporary Income Tax Regs., 53 Fed. Reg. 22163, 22165…
1Opinion of the Court
Halpern, Judge:
Petitioner is the common parent corporation of an affiliated group of corporations making a consolidated return of income (the affiliated group). By notice of deficiency dated September 29, 1995 (the notice), respondent determined deficiencies in Federal income tax for the affiliated group for its taxable years ended February 1, 1992, and January 30, 1993 (1992 and 1993, respectively), in the amounts of $72,040,547 and $95,836,934, respectively. Many of the adjustments giving rise to the deficiencies determined in the notice have been settled, and this report addresses only…
2Cases cited10 opinions
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Public Citizen v. United States Department of JusticeSupreme Court of the United States · 1989
- Nationsbank of North Carolina, N. A. v. Variable Annuity Life InsuranceSupreme Court of the United States · 1995
- Marquette National Bank of Minneapolis v. First of Omaha Service Corp.Supreme Court of the United States · 1978
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