Coca-Cola Co. v. United States

WHITAKER, Judge.

In the year 1933 the plaintiff, incorporated under the laws of Delaware, owned all of the stock of The Coca-Cola Company of Canada, Ltd. In that year it received from its Canadian subsidiary dividends of $6,429,201.62 in Canadian currency. In United States currency this amounted to $5,732,378.87.

The question presented is the credit to which plaintiff is entitled for foreign taxes paid by its subsidiary on the earnings out of which these dividends were paid.

Section 131 of the Revenue Act of 1932, 47 Stat. 169, 211, 212, 26 U.S.C.A. Int.Rev. Acts, page 531, allows a taxpayer a…