American Chicle Co. v. United States

The question in this case is the proper method of computing the credit to which an American corporation is entitled on its American income tax when it has received dividends from a foreign subsidiary which has paid income taxes to a foreign government upon the income a part of which has come to the American corporation as dividends.

*706Pertinent portions of the Kevenue Act of 1936, some of the language of which is here under consideration, are as follows:

Sec. 131. (f) Taxes of Foreign Subsidiary. — For the-purposes of this section a domestic corporation which owns a majority of the voting stock…