American Chicle Co. v. United States

*602The opinion of the Supreme Court was delivered by

Mr. Justice Roberts,

as follows:

This case involves the application of Section 131 (f) of the Revenue Acts of 1936 and 19381 which allows a tax credit to domestic corporations in respect of income received from foreign subsidiaries.

During the taxable years 1936,1937, and 1938, the petitioner, a domestic corporation, received dividends from foreign subsidiaries of which it was sole stockholder. The subsidiaries paid taxes upon their earnings to the countries of their domicile. In its income tax returns the petitioner claimed the credit allowed by…