26 U.S.C. § 27
Taxes of foreign countries and possessions of the United States
The amount of taxes imposed by foreign countries and possessions of the United States shall be allowed as a credit against the tax imposed by this chapter to the extent provided in section 901 1
Notes of Decisions
Cited in 12
cases (2 in the last 5 years), 1935–2024 · leading case: Kappus v. Comm'r, 337 F.3d 1053 (D.C. Cir. 2003).
Kappus v. Comm'r, 337 F.3d 1053 (D.C. Cir. 2003). “See 26 U.S.C. §§ 27 (a), 901. In addition to the regular tax, the Kappus-es were subject to the alternative minimum tax (AMT) imposed by 26 U.”
Salem Fin., Inc. v. United States, 112 Fed. Cl. 543 (Fed. Cl. 2013). “Since 1918, however, the United States has allowed domestic taxpayers in this circumstance to claim a dollar-for-dollar credit in the U.”
E. L. Bride, Individually, & E. L. Bride, Transferee, & E. L. Bride Co. by E. L. Bride, Tr. v. Comm'r of Internal Revenue, 224 F.2d 39 (8th Cir. 1955). “The claim made by petitioners in their pleadings before the Tax Court with respect to the allowance of the liquidating distribution as a credit under Section 27(g) was related to the second taxable period of the corporation as to which the Commissioner had originally sought to…”
Gen. Elec. Co. v. The United States, 299 F.2d 942 (Ct. Cl. 1962). “Section 27 of the Internal Revenue Code of 1939, 26 U.S.C. § 27 reads, in part, as follows: “(d) Dividends in kind.”
Fulman v. United States, 407 F. Supp. 1039 (D. Mass. 1976). “26 U.S.C. § 27 (d) (1952). 5 The valuation *1042 standard of section 27(d) relevant to the issue here is embodied in the Treasury Regulation, 26 C.”
Fisher v. Kavanagh, 100 F. Supp. 248 (E.D. Mich. 1951). “rly chargeable to earnings or profits accumulated after February 28, 1913, because the deficit in accumulated earnings or profits of Nor-walk Corporation at July 31, 1945, was greater than the earnings or profits of the taxable period, August 1, 1945, through May 31, 1946, and…”
Int'l Bedaux Co., Inc. v. Comm'r of Internal Revenue, 204 F.2d 870 (2d Cir. 1953). “It appears to be clear that no formal declaration of dividends was needed -under the circumstances; and any showing of payment of the dividends, actual or “constructive,” would be sufficient to allow the credit of dividends paid as providedt in I.”
Clark v. Restaino (D. Idaho 2022). “The ATF cannot approve an application to make a firearm “if the making or possession of the firearm would place the person making the firearm in violation of law.”
Bruyea v. United States (Fed. Cl. 2024). “]” 26 U.S.C. § 27 (emphasis added). Section 27 is in Chapter 1 of the I.”
United States v. Wilson, 9 F. Supp. 968 (W.D.N.Y. 1935). “(26 USCA § 27). The Maryland collector had no authority to appoint deputy collectors in excess of 15 per cent, of the number he had theretofore had in his employ.”
Salem Fin., Inc. v. United States (Fed. Cl. 2013). “Since 1918, however, the United States has allowed domestic taxpayers in this circumstance to claim a dollar-for-dollar credit in the U.S. for income taxes they have paid in a foreign country.”
Salem Fin., Inc. v. United States (Fed. Cl. 2013). “Since 1918, however, the United States has allowed domestic taxpayers in this circumstance to claim a dollar-for-dollar credit in the U.S. for income taxes they have paid in a foreign country.”
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