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foreign tax credit it claimed in connection with its Brazilian
loans by an amount equal to the pecuniary benefit provided by the
Brazilian Government to Brazilian borrowers.
In its amended petition, petitioner asserted, among other
things, that the foreign tax credit otherwise allowable to it for
1980 through 1986 should not be reduced by the pecuniary benefit
provided to Brazilian borrowers.
The total foreign tax credit claimed by petitioner for 1980
through 1986 that is still in dispute between the parties, and the
amounts of the disputed credit attributable to the legal liability,
Central Bank, and subsidy/pecuniary benefit issues, are as follows:
Issues
Total Subsidy/Pecuniary
Year Credit Legal Liability Central Bk Benefit
1980 $53,358 $53,358 -- $21,343
1981 545,462 545,462 -- 218,185
1982 814,969 814,969 -- 325,988
1983 489,341 489,341 -- 195,736
1984 312,353 312,353 $166,415 124,941
1985 242,781 242,781 181,272 93,506
1986 355,679 355,679 317,019 --
OPINION
Section 901 allows a domestic corporation to claim as a credit
against its Federal income tax (subject to certain limitations not
applicable herein) the amount of any income taxes paid on behalf of
the taxpayer to a foreign country. Sec. 4.901-2(a), Temporary
Income Tax Regs., 45 Fed. Reg. 75648 (Nov. 17, 1980); sec. 1.901-
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