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COCA-COLA CO. v. UNITED STATES

No. 45226.

55 F.Supp. 616 (1944)

COCA-COLA CO. v. UNITED STATES.

Court of Claims.

June 5, 1944.

Attorney(s) appearing for the Case

John E. McClure, of Washington, D. C. (O. H. Chmillon, Maud Ellen White, and Miller & Chevalier, all of Washington, D. C., and Spalding, Sibley & Troutman, of Atlanta, Ga., on the brief), for appellant.

Elizabeth B. Davis, of Washington, D. C., and Samuel O. Clark, Jr., Asst. Atty. Gen. (Fred K. Dyar, of Washington, D. C., on the brief), for defendant.

Before WHALEY, Chief Justice, and LITTLETON, WHITAKER, JONES, and MADDEN, Judges.

WHITAKER, Judge.

In the year 1933 the plaintiff, incorporated under the laws of Delaware, owned all of the stock of The Coca-Cola Company of Canada, Ltd. In that year it received from its Canadian subsidiary dividends of $6,429,201.62 in Canadian currency. In United States currency this amounted to $5,732,378.87.

The question presented is the credit to which plaintiff is entitled for foreign taxes paid by its subsidiary...

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