Aluminum Co. v. United States

McVICAR, District Judge.

The Aluminum Company of America, plaintiff, is a corporation of the Commonwealth of Pennsylvania. The Aluminum Company of Canada, Limited, is a Canadian corporation, all of the voting stock of which was owned by plaintiff in the year 1927. In that year, the plaintiff received from the *24Aluminum Company of Canada, Limited, a dividend in the amount of $1,000,000. In that year, the total profits of the Aluminum Company of Canada, Limited, was $2,897,-101.63, upon which it paid income, war profits, or excess profits taxes to the Dominion of Canada, or provinces thereof,…