Crestek, Inc. & Subsidiaries v. Comm'r
United States Tax Court
P is the parent of a group of companies that includes a number of controlled foreign corporations (CFCs). Before FY 2008 one of P's domestic subsidiaries (S1) borrowed money from the CFCs, and those loans remained outstanding throughout FY 2008 and 2009. S1 before FY 2008 also borrowed money from a Malaysian bank. CFC-1, P's Malaysian subsidiary, guaranteed this loan.
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P is the parent of a group of companies that includes a number of controlled foreign corporations (CFCs). Before FY 2008 one of P's domestic subsidiaries (S1) borrowed money from the CFCs, and those loans remained outstanding throughout FY 2008 and 2009. S1 before FY 2008 also borrowed money from a Malaysian bank. CFC-1, P's Malaysian subsidiary, guaranteed this loan. Before mid-2005 CFC-1 sold completed products to another domestic subsidiary (S2), for which S2 incurred payment obligations in the form of trade receivables. CFC-1 ceased manufacturing operations in mid-2005. The net trade…
1Opinion of the Court
CRESTEK, INC. & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Crestek, Inc. & Subsidiaries v. Comm'r
Docket No. 8285-13
United States Tax Court
2017 U.S. Tax Ct. LEXIS 38; 149 T.C. No. 5;
July 27, 2017, Filed
An order will be issued granting in part and denying in part respondent's motion for partial summary judgment.
P is the parent of a group of companies that includes a number of controlled foreign corporations (CFCs). Before FY 2008 one of P's domestic subsidiaries (S1) borrowed money from the CFCs, and those loans remained outstanding throughout FY 2008 and 2009. S1…
2Cases cited12 opinions
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Dahlstrom v. CommissionerUnited States Tax Court · 1985
- FPL Group, Inc. v. CommissionerUnited States Tax Court · 2001
- Elec. Arts, Inc. v. Comm'rUnited States Tax Court · 2002
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