26 U.S.C. § 902
Repealed. Pub. L. 115–97, title I, § 14301(a), Dec. 22, 2017, 131 Stat. 2221]
[repealed]
Notes of Decisions
Cited in 27
cases, 1932–2015 · leading case: United States v. Goodyear Tire & Rubber Co., 493 U.S. 132 (1990).
United States v. Goodyear Tire & Rubber Co., 493 U.S. 132 (1990). “In this case, we must decide whether “accumulated profits” in the indirect tax credit provision of the Internal Revenue Code of 1954, 26 U. S. C. § 902 (1970 ed.), are to be measured in accordance with United States or foreign tax principles.”
PPL Corp. v. Comm'r of Internal Revenue, 133 S. Ct. 1897 (2013). “132, 145 (1989) (noting in interpreting 26 U. S. C. §902 that Biddle is particularly applicable “where a contrary interpretation would leave” tax interpretation “to the varying tax policies of foreign tax authorities”); Heiner v.”
Albemarle Corp. & Subsidiaries v. United States, 118 Fed. Cl. 549 (Fed. Cl. 2014). “” 26 U.S.C. § 902 (e)(4)(A) (2012). Treasury Regulation § 1.”
Dresser Indus., Inc. v. United States, 238 F.3d 603 (5th Cir. 2001). “As that court explained, The word “deemed” is used interchangeably with the words “treated as” in a closely associated provision of the Code, 26 U.S.C. § 902 (a), and the legislative history of section 904(c) confirms that the statute uses the word “deemed” in that sense.”
Bank of New York Mellon Corp. v. Comm'r of Internal Revenue, 801 F.3d 104 (2d Cir. 2015). “26 U.S.C. §§ 902 , 960. Thus, *108 in a given tax year, a U.”
Goodyear Tire & Rubber Co. v. United States, 14 Cl. Ct. 23 (Ct. Cl. 1987). “TIDWELL, III, Judge: This tax refund case came before the court for disposition on plaintiff's motion for summary judgment to determine whether foreign tax law concepts are controlling when computing indirect tax credits under section 902 of the Internal Revenue Code of 1954, 26…”
Xerox Corp. v. United States, 41 F.3d 647 (Fed. Cir. 1995). “§ 901 for income taxes paid to a foreign government when a domestic corporation owns at least 10 percent of the voting stock of a foreign corporation from which it receives dividends in any *659 taxable year. The Treaty, by defining ACT as an income tax, brought ACT within the…”
Snap-On Tools, Inc. v. United States, 26 Cl. Ct. 1045 (Ct. Cl. 1992). “Moreover, the only issue briefed in the cross motions for summary judgment, and argued by the parties to the court, is regarding the reconcilability of the 60-day rule included in section 902(c)(1) of the Internal Revenue Code of 1954 (IRC) 4 26 U.S.C. § 902 (c)(1), and the…”
Fluor Corp. & Affiliates v. United States, 126 F.3d 1397 (Fed. Cir. 1997). “The word “deemed” is used interchangeably with the words “treated as” in a closely associated provision of the Code, 26 U.S.C. § 902 (a), and the legislative history of section 904(c) confirms that the statute uses the word “deemed” in that sense.”
Avon Prods., Inc. & U.S. Subsidiaries v. United States, 97 F.3d 1435 (Fed. Cir. 1996). “Those employee profit participation payments (or EPP payments) are central to this dispute because of their impact on the foreign tax credit made available to Avon by section 902 of the Internal Revenue Code, 26 U.S.C. § 902 . Under section 902, a U.”
Flint Resources Co. v. State ex rel. Oklahoma Tax Comm'n, 780 P.2d 665 (Okla. 1989). “The Income Tax Act of 1954, 26 U.S.C. § 902 (a) (1981) provides: "(a) Treatment of taxes paid by foreign corporation.”
Associated Tel. & Tel. Co., & Cross v. United States of Am., & Cross, 306 F.2d 824 (2d Cir. 1962). “Code of 1954 § 902(a), 26 U.S.C.A. § 902 (a). Accordingly, the taxpayer claimed a foreign tax credit, pursuant to Int.”
— 26 U.S.C. § 902(b) — 1 case
B. F. Avery & Sons Co. v. Glenn, 106 F.2d 613 (6th Cir. 1939).
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