Union Assurance Society, Ltd. v. United States

48 F. Supp. 665, 99 Ct. Cl. 218, 30 A.F.T.R. (P-H) 899, 1943 U.S. Ct. Cl. LEXIS 125
CourtUnited States Court of Claims
DecidedFebruary 1, 1943
DocketNo. 45456
StatusPublished

This text of 48 F. Supp. 665 (Union Assurance Society, Ltd. v. United States) is published on Counsel Stack Legal Research, covering United States Court of Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Union Assurance Society, Ltd. v. United States, 48 F. Supp. 665, 99 Ct. Cl. 218, 30 A.F.T.R. (P-H) 899, 1943 U.S. Ct. Cl. LEXIS 125 (cc 1943).

Opinions

Jones, Judge,

delivered the opinion of the court:

This is a suit by a British insurance corporation, other than life or mutual, for refund of income taxes paid for the years 1930, 1931, and 1932. It is based on an alleged error of the Commissioner of Internal Revenue in limiting deductions for British income taxes paid to an amount not in excess of that resulting from applying the British tax rate to the income of plaintiff from sources within the United States.

[227]*227The question is whether such a maximum limit of the allowance for deduction is proper under the applicable statute.

Pertinent parts of the statutes and regulations involved are set out in the footnote.1

Plaintiff, an insurance company, other than life or mutual, conducts an insurance business- in various countries and is affiliated with twenty-two other companies which also engage in insurance business in different parts of the world. The principal office of the group is in London, England.

[228]*228Plaintiff, for each of the years involved, filed United States income tax returns showing gross income from all sources and gross income from sources within the United States with supporting schedules, from which it computed a net taxable income for each year from sources within the United States. In arriving at the net taxable income, each of the returns reflected a deduction from gross income from sources within the United States for a part of the British income tax paid by the consolidated group. The United States Commissioner of Internal Revenue required that plaintiff file with its returns, in substantiation of its deductions for British income taxes, (1) a schedule of its gross income from all sources, reconciled with its annual financial statement, (2) a statement showing its net income from all sources subject to British income tax, and (3) a schedule of the consolidated assessment, showing the net taxable income or loss of each of the twenty-three companies in the consolidated group of which plaintiff is a member, together with all adjustments producing the consolidated tax liability, and (4) receipts for payment of the consolidated assessment. The plaintiff complied with these requirements.

[With some adjustments which are not now in controversy, the plaintiff determined its deduction for British income taxes in its United States returns by applying to the total British income taxes paid by it on income from all sources as a member of the consolidated group the percentage which its gross income from sources within the United States bore to its total gross income from all sources, the total British tax paid by plaintiff having been determined by applying to the total tax paid by the consolidated group the percentage which the taxed income of plaintiff bore to the taxed income of the consolidated group. The Commissioner’s computation made use of the ratio method followed by plaintiff but in addition placed as a limitation thereon a maximum allowance determined by applying the British income tax rate of 25 percent to plaintiff’s actual United States net taxable income without deduction for British income taxes and exclusive of United States income from which British tax was withheld at the source. Our [229]*229question is whether the limitation applied by the Commissioner was proper.]

Apparently the British permit an affiliated group operating in many countries to file a return showing aggregate net gains and losses as one taxpayer. In America while an affiliated group may file a consolidated return, each of the group remains a taxpayer. Woolford Realty Co. v. Rose, 286 U. S. 319; Swift & Co. v. United States, 69 C. Cls. 171, 38 F. (2d) 365.

It seems proper that some limitation should be placed upon the amount of foreign taxes paid by a member of a consolidated group which that member may deduct from income received from sources within the United States. Otherwise it is conceivable that there might be a considerable income from operations in the United States and yet the aggregate net gains or losses from operations elsewhere be so great that unrestricted deductions applied on a strictly ratable basis might completely offset the United States income so that no tax whatever would be paid on such income. This would present the anomaly of a foreign corporation doing business in the United States and receiving a substantial income (profit) therefrom and yet paying no income tax whatever to the United States.

To prevent such a distortion of American income tax deductions the Commissioner of Internal Revenue, in construing Sections 119 and 232 of the Revenue Acts of 1928 and 1932, adopted what he called a “limitation” on deductions for British, income taxes specifying that no deduction may be allowed in excess of the amount of income taxes that would have been actually due had the British rate been applied to income from sources within the United States. In the case at bar the limitation was made use of by applying the British tax rate of 25 percent to the United States income subject to United States tax instead of to the United States income which was subjected to the British tax under the British concept of taxable income. The plaintiff has not attempted to show what variation, if any, existed between the two incomes. In effect, what plaintiff argues is that the deduction should be unreservedly determined on the ratio basis without any limitation.

[230]*230Plaintiff suggests that the Commissioner of Internal Revenue used a different method for calculating taxes for different years, depending on which one would secure the most money for the Government. This is incorrect. Exactly the same method was used for each of the six years 1928 to 1933 inclusive. For each of those years the ratio method of apportioning deductions was used. The overall British tax rate was used as a limitation for the years when the deductions claimed reached that amount. The British tax rate was applied not as a method but as a limitation. Of course, in any year when the deductions claimed were less than the British tax rate the limitation, though still in force, did not affect the result. The uniform method was used for all the years.

It is as if a dam has a spillway and the parties at interest have a contract that an owner below is entitled to all water that runs over the spillway. The fact that in certain years no water runs over the spillway doesn’t alter the agreement. The same agreement prevails in each year even though the spillway is in actual use only in certain years. It is there and in effect for every year, regardless of whether any water actually runs over it.

Likewise here the limitation was made effective for all years even though the claim for deduction reached the level of the spillway or limitation only in certain years. To use another illustration, it operated in the same fashion as the governor on an engine, which prevents excessive speed without in any way interfering with the uniform principle upon which the engine operates.

Naturally the defendant did not allow as a deduction for any year a greater amount than its proportion of expenses and losses. Only when the claims reached unjust figures did the limitation, though in force at all times, affect the result.

Was the Commissioner justified in applying such a limitation ? We think he was. Certainly some limitation should be placed on such deductions.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Two Hundred Barrels of Whiskey
95 U.S. 571 (Supreme Court, 1877)
Maryland Casualty Co. v. United States
251 U.S. 342 (Supreme Court, 1920)
International Railway Co. v. Davidson
257 U.S. 506 (Supreme Court, 1922)
Woolford Realty Co. v. Rose
286 U.S. 319 (Supreme Court, 1932)
Swift & Co. v. United States
38 F.2d 365 (Court of Claims, 1930)
Third Scottish American Trust Co. v. United States
37 F. Supp. 279 (Court of Claims, 1941)

Cite This Page — Counsel Stack

Bluebook (online)
48 F. Supp. 665, 99 Ct. Cl. 218, 30 A.F.T.R. (P-H) 899, 1943 U.S. Ct. Cl. LEXIS 125, Counsel Stack Legal Research, https://law.counselstack.com/opinion/union-assurance-society-ltd-v-united-states-cc-1943.