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CONTAINER CORP. v. COMMISSIONER

Docket No. 3607-05.

134 T.C. 122 (2010)

CONTAINER CORPORATION, SUCCESSOR TO INTEREST OF CONTAINER HOLDINGS CORPORATION, SUCCESSOR TO INTEREST OF VITRO INTERNATIONAL CORPORATION, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed February 17, 2010.

Attorney(s) appearing for the Case

Emily A. Parker, for petitioner.

Dennis M. Kelly, for respondent.

OPINION

HOLMES, Judge:

The Code puts a 30-percent tax on "fixed or determinable annual or periodical" income received by foreign corporations from sources within the United States. Vitro, S.A. is a Mexican corporation that charged one of its U.S. subsidiaries a fee to guarantee the subsidiary's debt to U.S. lenders. The question presented in this case is whether that fee is from a source within the United States.

Background

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