 For the purposes of this section, a domestic corporation which owns a majority of the voting stock of a foreign corporation from which it receives dividends in any taxable year shall be deemed to have paid the same proportion of any income, war-profits,...  Reports of the Tax Court of the United States - Page 209by United States. Tax Court - 1945Full view - About this book
 | United States. Court of Claims - 1942 - 818 pages
...consideration, are as follows : SEC. 131. (f ) Taxes of Foreign Subsidiary. — For the purposes of this section a domestic corporation which owns a majority of the...the same proportion of any income, war-profits, or etecess-profits tasoes paid by such foreign corporation to any foreign country or to any possession... | |
 | United States. Court of Claims - 1943 - 672 pages
...that, for the purpose of the section, a domestic corporation receiving dividends from such a subsidiary "in any taxable year shall be deemed to have paid...income, war-profits, or excess-profits taxes paid" by the subsidiary to a foreign country, "upon or with respect to the accumulated profits" of the subsidiary... | |
 | United States. Court of Claims - 1937 - 786 pages
...with a foreign corporation should be determined, provided that — For the purposes of section 238 a domestic corporation which owns a majority of the voting stock of a foreign corporation shall be deemed to have paid the 78975— 37— cc— vol. 83 37 Opinion of the Court same proportion... | |
 | United States. Court of Claims - 1940 - 772 pages
...section 238 a domestic corporation which owns a majority of the voting stock of a foreign corporation shall be deemed to have paid the same proportion of any income, war-profits, and excess-profits taxes paid (but not including taxes accrued) by such foreign corporation during... | |
 | Philippines - 1986 - 492 pages
...and computation of such credits. (8) Taxes of foreign subsidiary. — For purposes of this subsection a domestic corporation, which owns a majority of the...deemed to have paid the same proportion of any income, war profits, or excess profits taxes paid by such foreign corporation to any foreign country, upon... | |
 | Robert Hiester Montgomery - 1920 - 1304 pages
...such foreign corporation in a consolidated return, but for the purpose of section 238 of the statute a domestic corporation which owns a majority of the voting stock of a foreign corporation shall be entitled to credit its income, war profits and excess profits taxes with any income, war profits... | |
 | Ewell D. Moore - 1919 - 44 pages
...corporations is owned or controlled by the same interests. (c) For the purposes of sec. 238 (credit for taxes) a domestic corporation which owns a majority of the voting stock of a foreign corporation is deemed to have paid the same proportion of any income, war profits and excess-profits taxes paid... | |
 | National City Company, United States - 1919 - 104 pages
...owned or controlled by the same interests. 180. (c) For the purposes of Section 238 (par. 170-173) a domestic corporation which owns a majority of the voting stock of a foreign corporation shall be deemed to have paid the same proportion of any income, war-profits and excess-profits taxes... | |
 | Harris, Forbes & co., New York - 1919 - 164 pages
...more corporations is owned or controlled by the same interests. (c) For the purposes of section 238 a domestic corporation which owns a majority of the voting stock of a foreign corporation shall be deemed to have paid the same proportion of any income, war-profits and excess-profits taxes... | |
 | Prentice-Hall Inc, Prentice-Hall, inc - 1919 - 640 pages
...include the net income or invested capital of such foreign corporation in a conslidated return, but a domestic corporation which owns a majority of the voting stock of a foreign corporation is entitled to certain credits for income, war profits and excess profits taxes paid by such foreign... | |
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