26 U.S.C. § 991
Taxation of a domestic international sales corporation
For purposes of the taxes imposed by this subtitle upon a DISC (as defined in section 992(a)), a DISC shall not be subject to the taxes imposed by this subtitle.
Notes of Decisions
Cited in 11
cases, 1931–2018 · leading case: Summa Holdings v. Comm'r of Internal Revenue, 848 F.3d 779 (6th Cir. 2017).
Summa Holdings v. Comm'r of Internal Revenue, 848 F.3d 779 (6th Cir. 2017). “The DISC pays no tax on its commission income (up to $10,000,000), 26 U.S.C. §§ 991 , 995(b)(1)(E), and may hold onto the money indefinitely, though the DISC shareholders must pay annual interest on their shares of the deferred tax liability, id.”
Benenson v. Comm'r of Internal Revenue, 887 F.3d 511 (1st Cir. 2018). “26 U.S.C. § 991 . 2 Once a DISC receives funds from the commissions, it may, if it chooses, issue dividends to its shareholders.”
SLI Int'l Corp. v. Crystal, 671 A.2d 813 (Conn. 1996). “The fundamental differences between DISCs and FSCs, reflected in the history of their creation, cause Bolt Technology Corp. to be unpersuasive. Congress created the DISC in 1971 as a means of encouraging exports.”
Computervision Corp. v. United States, 445 F.3d 1355 (Fed. Cir. 2006). “26 U.S.C. § 991 (2000). Instead, a portion of the DISC’S earnings is taxed to the DISC’S shareholders as a constructive dividend, 26 U.”
Bowater, Inc. & Subsidiaries, Formerly Known as Bowater Holdings, Inc. v. Comm'r of Internal Revenue, 108 F.3d 12 (2d Cir. 1997). “See 26 U.S.C. §§ 991 , 995(b), (c). To compute the amount of its DISCs’ income, Taxpayer used the “50/50 combined taxable income” method set forth in § 994(a)(2).”
Thomas Int'l Ltd. v. United States, 6 Cl. Ct. 414 (Ct. Cl. 1984). “Plaintiff is entitled to refund of this sum with interest from March 8, 1981, as provided by law, and the clerk is directed to enter judgment accordingly.”
Gen. Motors Corp. v. Arizona Dep't of Revenue, 938 P.2d 481 (Ariz. Ct. App. 1996). “Specifically, 26 U.S.C. §§ 991 through 997 of the I.R.C.”
Nw. Utils. Sec. Corp. v. Helvering, 67 F.2d 619 (8th Cir. 1933). “title 26, § 991, 26 USCA § 991], and 1926, supra; section 52 [a] of the Revenue Acts of 1928, c.”
Westinghouse Elec. Corp. v. Comm'r of Revenue, 398 N.W.2d 530 (Minn. 1986). “WEEX was created on December 22, 1971, as a domestic international sales corporation (DISC) for federal income tax purposes under 26 U.S.C. §§ 991 , et seq. (1982) and was so treated for the years 1972 through 1976.”
Beneficial Loan Soc. of Bethlehem v. United States, 48 F.2d 686 (Ct. Cl. 1931). “45 (26 USCA § 991), provides: “Returns made under this section shall be subject to the provisions of section 226.”
Nat'l Paper Prods. Co. v. Helvering, 69 F.2d 857 (9th Cir. 1934). “However, section 239 of that Act (26 USCA § 991) provides that “every corporation subject to taxation under this chapter shall make a return, stating specifically the items of its gross income a,nd the deductions and credits allowed by this chapter,” etc.”
Annotations are extracted automatically from the opinions in the
Syfert caselaw corpus and ranked by authority, recency, and
treatment. Dots show Syfertize treatment of the citing case itself.