International Multifoods Corp. v. Commissioner
United States Tax Court
On Mar. 30, 1987, P, a domestic corporation, entered into an agreement with Borden to sell P's stock in Paty, a limitada organized under the laws of the Federal Republic of Brazil. P realized a loss upon the sale of the Paty stock, which P reported as a U.S. source loss for purposes of its foreign tax credit computation under sec. 904(a), I.R.C. R determined that the loss was foreign source. Held: P's loss is sourced in the United States.
Read the full summary
On Mar. 30, 1987, P, a domestic corporation, entered into an agreement with Borden to sell P's stock in Paty, a limitada organized under the laws of the Federal Republic of Brazil. P realized a loss upon the sale of the Paty stock, which P reported as a U.S. source loss for purposes of its foreign tax credit computation under sec. 904(a), I.R.C. R determined that the loss was foreign source. Held: P's loss is sourced in the United States. Sec. 865, I.R.C., which provides that income from the sale of noninventory personal property is generally sourced at the residence of the seller, is also…
1Opinion of the Court
INTERNATIONAL MULTIFOODS CORPORATION AND AFFILIATED COMPANIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
International Multifoods Corp. v. Commissioner
Docket No. 11643-92
United States Tax Court
108 T.C. 579; 1997 U.S. Tax Ct. LEXIS 25; 108 T.C. No. 26;
June 18, 1997, Filed
Decision will be entered under Rule 155.
On Mar. 30, 1987, P, a domestic corporation, entered into an agreement with Borden to sell P's stock in Paty, a limitada organized under the laws of the Federal Republic of Brazil. P realized a loss upon the sale of the Paty stock, which P reported as a U.S. source loss…
2Cases cited9 opinions
- First Chicago Corporation v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1988
- Occidental Petroleum Corp. v. CommissionerUnited States Tax Court · 1984
- First Chicago Corp. v. CommissionerUnited States Tax Court · 1987
- The Black & Decker Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1993
- H Enters. Int'l v. CommissionerUnited States Tax Court · 1995
4 more not listed; retrieve them via the Exa API.