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" ... taxes paid by such foreign corporation to any foreign country or to any possession of the United States, upon or with respect to the accumulated profits of such foreign corporation from which such dividends were paid, which the amount of such dividends... "
Cases Decided in the Court of Claims of the United States - Page 739
by United States. Court of Claims - 1944
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Income Tax Procedure

Robert Hiester Montgomery - 1923 - 1760 pages
...paid by such foreign corporation to any foreign country or to any possession of the United States, upon or with respect to the accumulated profits of...amount of such accumulated profits: Provided, That the credit allowed to any domestic corporation under this subdivision shall in no case exceed the same...
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Statistics of Income for ...

1954 - 766 pages
...to any роажоыол of the United States, upon or with respect to the accumulated profits of the corporation from which such dividends were paid, which...the amount of such dividends bears to the amount of ouch accumulated profits. (g) Corporations Treated as Foreign— For the purpose* of this section the...
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Income Tax Procedure ...

Robert Hiester Montgomery - 1927 - 1510 pages
...dividend received from the foreign subsidiary. It has been suggested that the phrase in section 238 (e) "upon or with respect to the accumulated profits of...corporation from which such dividends were paid," might limit the credit for taxes as shown in the above illustration to an amount allocated to the $16,000...
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Income Tax Procedure ...

Robert Hiester Montgomery - 1927 - 1510 pages
...dividend received from the foreign subsidiary. It has been suggested that the phrase in section 238 (e) "upon or with respect to the accumulated profits of...foreign corporation from which such dividends were paid,1' might limit the credit for taxes as shown in the above illustration to an amount allocated...
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Regulations 74 Relating to the Income Tax Under the Revenue Act of 1928

United States. Internal Revenue Service - 1931 - 502 pages
...paid by such foreign corporation to any foreign country or to any possession of the United States, upon or with respect to the accumulated profits of...amount of such accumulated profits : Provided, That the credit allowed to any domestic corporation under this subsection shall in no case exceed the same proportion...
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Treasury Decisions Under Internal Revenue Laws of the United States, Volume 31

United States. Internal Revenue Service - 1932 - 192 pages
...such controlled foreign corporation to any foreign country or to any possession of the United States, upon or with respect to the accumulated profits of...which such dividends were paid, which the amount of any such dividends received bears to the amount of such accumulated profits. The credit for taxes deemed...
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United States Reports: Cases Adjudged in the Supreme Court at ..., Volume 285

United States. Supreme Court, John Chandler Bancroft Davis, Henry Putzel, Henry C. Lind, Frank D. Wagner - 1932 - 696 pages
...corporation " to any foreign country " upon the accumulated profits from which such dividends were paid, as the amount of such dividends bears to the amount of such accumulated profits. Held, construing it in connection with earlier legislation: (1) That the purpose is to mitigate the...
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United States Reports: Cases Adjudged in the Supreme Court at ..., Volume 285

United States. Supreme Court, John Chandler Bancroft Davis, Henry Putzel, Henry C. Lind, Frank D. Wagner - 1932 - 716 pages
...corporation " to any foreign country '' upon the accumulated profits from which such dividends were paid, as the amount of such dividends bears to the amount of such accumulated profits. Held, construing it in connection with earlier legislation: (1) That the purpose is to mitigate the...
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Regulations 77 Relating to the Income Tax Under the Revenue Act of 1932

United States. Bureau of Internal Revenue - 1933 - 452 pages
...such controlled foreign corporation to any foreign country or to any possession of the United States, upon or with respect to the accumulated profits of...which such dividends were paid, which the amount of any such dividends received bears to the amount of such accumulated profits. The amount of taxes deemed...
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Regulations 86 Relating to the Income Tax Under the Revenue Act of 1934

United States. Bureau of Internal Revenue, United States. Internal Revenue Service - 1935 - 502 pages
...paid by such foreign corporation to any foreign country or to any possession of the United States, upon or with respect to the accumulated profits of such foreign corporation from which siich dividends were paid, which the amount of such dividends bears to the amount of such accumulated...
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