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PITTWAY CORP. v. U.S.

No. 95-2239.

88 F.3d 501 (1996)

PITTWAY CORPORATION and Subsidiaries, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided July 8, 1996.

Attorney(s) appearing for the Case

Todd F. Maynes (argued), Lee Radford, Kirkland & Ellis, Chicago, IL, for plaintiff-appellant.

Gary R. Allen, David E. Carmack, Steven W. Parks (argued), Edward T. Perelmuter, Dept. of Justice, Tax Div., Appellate Section, Washington, DC, Michele M. Fox, James B. Burns, Office of U.S. Atty., Civ. Div., Appellate Section, Chicago, IL, for defendant-appellee.

Before EASTERBROOK, RIPPLE and DIANE P. WOOD, Circuit Judges.

DIANE P. WOOD, Circuit Judge.

In the field of tax law, timing often has drastic consequences. In this case, we must cross the Atlantic Ocean and consult the law of France to see when Pittway's 90% owned subsidiary, Valois S.A., declared a share dividend, which in turn governs the tax treatment of Valois's distribution to its shareholders and ultimately Pittway's own tax liability. We conclude that the district court correctly rejected Pittway's interpretation of the...

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