Vulcan Materials Co. v. Commissioner
United States Tax Court
P was a 48-percent shareholder and two other U.S. corporations were each 10-percent shareholders in TVCL, a Saudi Arabian corporation, the remaining shareholders being Saudi Arabian nationals. The Saudi Arabian income tax was imposed only on the income allocable to the 68-percent interest of the U.S. shareholders, the Saudi Arabian shareholders being subjected to a capital tax.
Read the full summary
P was a 48-percent shareholder and two other U.S. corporations were each 10-percent shareholders in TVCL, a Saudi Arabian corporation, the remaining shareholders being Saudi Arabian nationals. The Saudi Arabian income tax was imposed only on the income allocable to the 68-percent interest of the U.S. shareholders, the Saudi Arabian shareholders being subjected to a capital tax. Held, the term "accumulated profits" in the denominator of the fraction utilized to determine the indirect foreign tax credit under sec. 902, I.R.C., includes only that portion of such profits of TVCL allocable to the…
1Opinion of the Court
OPINION
TANNENWALD, Judge:
Respondent determined a deficiency in petitioner’s 1984 Federal income tax in the amount of $133,679. The sole issue for decision is the amount of Saudi Arabian taxes that petitioner should be deemed to have paid under section 9021 for the purpose of determining its foreign tax credit.
All of the facts have been stipulated, and the stipulation of facts and attached exhibits are incorporated herein by reference.
Petitioner is a domestic corporation with its principal corporate offices in Birmingham, Alabama, which, along with certain of its subsidiaries, filed a…
2Cases cited12 opinions
- United States v. Jefferson Electric Manufacturing Co.Supreme Court of the United States · 1934
- Biddle v. CommissionerSupreme Court of the United States · 1938
- Blair v. Oesterlein MacHine Co.Supreme Court of the United States · 1927
- Stubbs, Overbeck & Associates, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- Cal-Maine Foods, Inc. v. CommissionerUnited States Tax Court · 1989
7 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Brunswick Corp. & Subsidiaries v. CommissionerUnited States Tax Court · 1993
- Central De Gas De Chihuahua, S.A. v. CommissionerUnited States Tax Court · 1994
- Brunswick Corp. & Subsidiaries v. CommissionerUnited States Tax Court · 1993
- Central De Gas De Chihuahua, S.A. v. CommissionerUnited States Tax Court · 1994
- Vulcan Materials Co. v. CommissionerUnited States Tax Court · 1991