TAIYO HAWAII CO. v. COMMISSIONER
United States Tax Court
P, a foreign corporation wholly owned by a foreign conglomerate, was engaged in real estate activity in Hawaii. P borrowed funds from foreign banks and also received advances from its parent and a related foreign corporation. Interest on bank borrowing was paid, and interest on advances from related corporations was accrued and not paid. P reported the interest as deductible.
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P, a foreign corporation wholly owned by a foreign conglomerate, was engaged in real estate activity in Hawaii. P borrowed funds from foreign banks and also received advances from its parent and a related foreign corporation. Interest on bank borrowing was paid, and interest on advances from related corporations was accrued and not paid. P reported the interest as deductible. After an audit examination, respondent determined that the accrued but unpaid interest was subject to the excess interest tax provided for in sec. 884, I.R.C. P, although reporting the advances from related corporations…
1Opinion of the Court
TAIYO HAWAII COMPANY, LTD., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
TAIYO HAWAII CO. v. COMMISSIONER
Docket No. 10159-95
United States Tax Court
108 T.C. 590; 1997 U.S. Tax Ct. LEXIS 39; 108 T.C. No. 27;
June 25, 1997, Filed
Decision will be entered for respondent.
P, a foreign corporation wholly owned by a foreign conglomerate, was engaged in real estate activity in Hawaii. P borrowed funds from foreign banks and also received advances from its parent and a related foreign corporation. Interest on bank borrowing was paid, and interest on advances from related corporations was…
2Cases cited45 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Fin Hay Realty Co. v. United StatesCourt of Appeals for the Third Circuit · 1968
- Ullman v. CommissionerCourt of Appeals for the Second Circuit · 1959
- Pritchett v. CommissionerUnited States Tax Court · 1974
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