Pittway Corporation and Subsidiaries v. United States

DIANE P. WOOD, Circuit Judge.

In the field of tax law, timing often has drastic consequences. In this case, we must cross the Atlantic Ocean and consult the law of France to see when Pittway’s 90% owned subsidiary, Valois S.A., declared a share dividend, which in turn governs the tax treatment of Valois’s distribution to its shareholders and ultimately Pittway’s own tax liability. We conclude that the district court correctly rejected Pittway’s interpretation of the Internal Revenue Code and the applicable French law, and we therefore affirm the judgment.

The underlying facts are…