Framatome Connectors USA, Inc., et al. v. CIR

BVLaw
Full Text of Court Cases
January 16, 2002
3670 Electrical and electronic equipment
423610 Electrical Apparatus and Equipment, Wiring Supplies, and Related Equipment Merchant Wholesalers
federal taxation

Framatome Connectors USA, Inc., et al. v. CIR
118 T.C. No. 3 (2002)
US
Federal Court
United States Tax Court
Mukesh Bajaj, Ph.d., Keith Reams, Masami Hashimoto
Colvin

Summary

The U.S. Tax Court considered whether Framatome’s subsidiary, Burndy-US’s 50% interest in Burndy-Japan was qualified to be treated as a controlled foreign corporation (CFC) for tax purposes.
Framatome Connectors USA, Inc., et al. v. CIR
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Control Premium Considered

The U.S. Tax Court considered whether the 50% interest Framatome’s subsidiary, Burndy-US, had in Burndy-Japan was qualified to be treated as a controlled foreign corporation (CFC) for tax purposes.