Brunswick Corp. & Subsidiaries v. Commissioner
United States Tax Court
P received a distribution from a foreign subsidiary which constituted an ordinary income dividend under sec. 1248, I.R.C., to the extent of the subsidiary's then accumulated profits at that time. The subsidiary had earnings and profits in some prior years and deficits in other such years.
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P received a distribution from a foreign subsidiary which constituted an ordinary income dividend under sec. 1248, I.R.C., to the extent of the subsidiary's then accumulated profits at that time. The subsidiary had earnings and profits in some prior years and deficits in other such years. Held, that, even though all the foreign subsidiary's accumulated profits were distributed as a dividend, all foreign taxes paid by the subsidiary in prior years cannot be aggregated and credited under sec. 902(a)(1), I.R.C.Held, further, the same principles for year-by-year sourcing of a dividend to…
1Opinion of the Court
BRUNSWICK CORPORATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Brunswick Corp. & Subsidiaries v. Commissioner
Docket No. 37357-87
United States Tax Court
100 T.C. 6; 1993 U.S. Tax Ct. LEXIS 1; 100 T.C. No. 2;
January 11, 1993, Filed
Decision will be entered under Rule 155.
P received a distribution from a foreign subsidiary which constituted an ordinary income dividend under sec. 1248, I.R.C., to the extent of the subsidiary's then accumulated profits at that time. The subsidiary had earnings and profits in some prior years and deficits in other such years. Held,…
2Cases cited18 opinions
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
- Burnet v. Chicago Portrait Co.Supreme Court of the United States · 1932
- American Chicle Co. v. United StatesSupreme Court of the United States · 1942
- Girard Trust Co. v. United StatesSupreme Court of the United States · 1926
- Bobsee Corporation v. United StatesCourt of Appeals for the Fifth Circuit · 1969
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