Compaq Computer Corporation and Subsidiaries v. Commissioner

113 T.C. No. 25

UNITED STATES TAX COURT COMPAQ COMPUTER CORPORATION AND SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 24238-96. Filed November 18, 1999. H, a U.K. corporation, paid a dividend to P, its U.S. parent. Upon payment of the dividend, H, pursuant to the law of the United Kingdom, became liable for and paid advance corporation tax (ACT) and became entitled to a credit against its U.K. corporate tax. H allocated the U.K. credit to its two wholly owned subsidiaries, S1 and S2, which used the U.K. credit against their respective mainstream corporate…