The Coca-Cola Company, and Includible Subsidiaries - Page 33

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          companies operating in the possessions originally were subjected            
          to double taxation by the imposition of both the Federal                    
          corporate income tax and the taxes levied by the possessions                
          governments.  Tariff Act of 1913, ch. 16, sec. II, 38 Stat. 166;            
          Revenue Act of 1918, ch. 18, 40 Stat. 1058.                                 
               Congress perceived that the tax burden so created placed               
          American businesses at a competitive disadvantage when compared             
          with their British and French counterparts not subject to                   
          taxation upon the profits they earned abroad unless paid back to            
          the home company.  Congress consequently enacted the original               
          version of section 931 to remove that competitive disadvantage.             
          H. Rept. 350, 67th Cong., 1st Sess. 1 (1921), 1939-1 C.B. (Part             
          2) 168, 174.                                                                
               Section 931 provided corporations an exclusion for                     
          possession-source income if they met the "80-percent source" test           
          and the "50-percent active trade or business" test.6  Because of            

               6Sec. 931 provided as follows:                                         
                    SEC. 931. INCOME FROM SOURCES WITHIN POSSESSIONS                  
               OF THE UNITED STATES.                                                  
                                                                                     
                         (a) General Rule.--In the case of                            
                    citizens of the United States or domestic                         
                    corporations, gross income means only gross                       
                    income from sources within the United States                      
                    if the conditions of both paragraph (1) and                       
                    paragraph (2) are satisfied:                                      
                             (1) Three-year period.--If 80 percent or                
                         more of the gross income of such citizen or                  
                         domestic corporation (computed without the                   
                                                             (continued...)           




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