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Full-Text Articles in Law
Conflict Of Laws-Full Faith And Credit-Extraterritorial Enforcement Of State Revenue Law, Edwin A. Howe Jr.
Conflict Of Laws-Full Faith And Credit-Extraterritorial Enforcement Of State Revenue Law, Edwin A. Howe Jr.
Michigan Law Review
As the operator of a parking lot within plaintiffs city limits, defendant was subject to a ten percent city tax on his gross receipts. He failed to report the whole of his receipts on his monthly tax returns, and plaintiff, the City of Philadelphia, duly notified him of a five thousand dollar deficiency. Defendant had a statutory right to petition for administrative review of the assessment within sixty days, failing which the liability would become fixed and no longer subject to review or appeal. Rather than appealing, defendant removed himself and his assets to New York, thus preventing plaintiff from …
Taxation-Federal Income Tax-Liquidation Distributions Entitled To Both Capital Gains Treatment And Foreign Tax Credit, Lloyd C. Fell
Taxation-Federal Income Tax-Liquidation Distributions Entitled To Both Capital Gains Treatment And Foreign Tax Credit, Lloyd C. Fell
Michigan Law Review
Plaintiff, Associated, is an American corporation whose wholly-owned subsidiary, Automatic, owned all the stock of Filcrest, a Canadian corporation. In 1954 all the assets of Filcrest were distributed to Automatic pursuant to a plan of complete liquidation, accomplished in accordance with Canadian law. In its 1954 consolidated return, plaintiff treated the gain realized on the Filcrest liquidation as a capital gain, and also claimed a foreign tax credit for any Canadian income, war or excess profits taxes which Filcrest had paid over the years to Canada on that part of the liquidation distribution which represented Filcrest's accumulated earnings and profits. …