26 U.S.C. § 936
Repealed. Pub. L. 115–141, div. U, title IV, § 401(d)(1)(C), Mar. 23, 2018, 132 Stat. 1206]
[repealed]
Notes of Decisions
Cited in 16
cases, 1933–2019 · leading case: Medchem (P.R.), Inc. v. Comm'r, 295 F.3d 118 (1st Cir. 2002).
Medchem (P.R.), Inc. v. Comm'r, 295 F.3d 118 (1st Cir. 2002). “This tax case requires interpretation of the Internal Revenue Code’s Puerto Rico and Possession Tax Credit provision, 26 U.S.C. § 936 (2000), which permits a domestic corporation to elect a possession tax credit if it meets certain conditions, id.”
Eli Lilly & Co. & Subsidiaries, Cross-Appellees v. Comm'r of Internal Revenue, Cross-Appellant, 856 F.2d 855 (7th Cir. 1988). “The current version of this investment incentive, which now takes the form of a tax credit instead of an exemption, appears at 26 U.S.C.A. § 936 (West Supp.1988). Since 1982, this section has included a provision, subsection 936(h), which permits possessions corporations to earn…”
amazon.com Inc. & Subsidiaries v. Cir, 934 F.3d 976 (9th Cir. 2019). “In 2017, Congress amended the definition of “intangible property” in 26 U.S.C. § 936 (h)(3)(B) (which is incorporated by reference in 26 U.”
Mercedes Santiago Hodge v. Parke Davis & Co., 909 F.2d 628 (1st Cir. 1990). “26 U.S.C. § 936 (a)(2). . Some employees’ relatives also appear as plaintiffs.”
Stand. Mfg. Co. v. Tax Comm'n, 114 A.D.2d 138 (N.Y. App. Div. 1986). “A large percentage of Caribbean’s profits remain undistributed in Puerto Rico in order to take advantage of the benefits of the Puerto Rican and possession tax credit ( 26 USC § 936 ). The Audit Division of the State Department of Taxation and Finance issued notices of…”
Bergersen v. Comm'r, 109 F.3d 56 (1st Cir. 1997). “26 U.S.C. § 936 (g). Meanwhile, starting in 1982, Earl Bergersen borrowed substantial amounts from the company, totaling almost $3,700,000 by 1987.”
Fed. Sav. & Loan Ins. v. Shearson-Am. Express, Inc., 658 F. Supp. 1331 (D.P.R. 1987). “possession corporations income tax exemption under 26 U.S.C. § 936 which are operating in the Commonwealth of Puerto Rico under its Industrial Tax Incentive Act (13 L.”
United States v. Larry Stuler, 396 F. App'x 798 (3rd Cir. 2010). “Staler argued that the United States lacked jurisdiction over him because he fulfilled the requirements of revocation pursuant to 26 U.S.C. § 936 (e)(2)(B). As the District Court explained, section 936, entitled “Puerto Rico and possession tax credit,” allows domestic…”
OMJ Pharm., Inc. v. United States, 753 F.3d 333 (1st Cir. 2014). “1755 , 1827, 26 U.S.C. § 936 (amended 2007). Under the transition rules, an existing credit claimant— that is, a taxpayer who previously claimed the credit, § 936(j)(9) — could continue to claim the credit for up to ten years, § 936(j)(3).”
F. T. Dooley Lumber Co. v. United States, 63 F.2d 384 (8th Cir. 1933). “9 , 16 [26 USCA § 936]) provides: “Whenever in the opinion of the commissioner the use of inventories is necessary in order clearly to determine the income of any taxpayer, inventories shall be taken by such taxpayer upon such basis as the commissioner, with the approval of the…”
Robles Melendez v. Merck & Co., Inc., 770 F. Supp. 71 (D.P.R. 1991). “After examining the general principles behind the PRWACA and analyzing the unique situation of Puerto Rico, where mainland corporations organize Puerto Rico subsidiaries in order to benefit from Section 936 of the Internal Revenue Code, 26 U.S.C. § 936 , 1 the Court concluded…”
Generadora De Electricidad Del Caribe v. Foster Wheeler Corp., 30 F. Supp. 2d 196 (D.P.R. 1998). “See 26 U.S.C. § 936 (1988). The above factual scenario strongly suggests that defendants’ contacts with the forum were not merely “incidental” or dealt with “hypothetical” discussions.”
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