- amounted to 8.3M - claimed for tax credit, dapat 15% lang daw dapat
ISSUE: 1) WON P&G PH is entitled to refund or credit?
SC - Yes!
US Internal Revenue Code, Sec 902:
- a domestic (US) corp owning 10% of remitting foreign corp shall be deemed to have paid a proportionate extent of taxes paid by such non-US corp upon remittance of dividends to US corp