Riggs National Corporation & Subsidiaries - Page 27




                                       - 27 -                                         
                             Year          Credit                                     
                             1984         $166,415                                    
                             1985          181,272                                    
                             1986          528,365                                    
              Following the Court of Appeals’ remand of this case, we                 
         instructed the parties to file written reports advising how we               
         should implement the Court of Appeals’ mandate.  The parties then            
         submitted to the Court their agreed proposal regarding the                   
         procedures to be used in implementing the mandate.  In accordance            
         with the parties’ agreement, we issued an order on May 12, 1999,             
         directing that the record in this case would not be reopened to              
         allow either party to introduce additional factual information,              
         documents, or testimony.                                                     
                                       OPINION                                        
              Section 901 allows a domestic corporation to claim the amount           
         of any income taxes paid or accrued during the taxable year to a             
         foreign country as a credit against its Federal income tax (subject          
         to certain limitations not applicable herein).  See sec. 901(b)(1).          
         The purpose of the credit is to reduce international double                  
         taxation.  See American Chicle Co. v. United States, 316 U.S. 450,           
         452 (1942).  In general, the person by whom foreign income tax is            
         considered paid is the person upon whom foreign law imposes legal            
         liability for the tax, even if another person (e.g., a withholding           
         agent) remits the tax.  See sec. 1.901-2(f)(1), Income Tax Regs.             
         Foreign income tax generally may be considered paid by a taxpayer            






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