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PNC FINANCIAL SERVICES GROUP, INC. v. C.I.R.

No. 06-1034.

503 F.3d 119 (2007)

PNC FINANCIAL SERVICES GROUP, INC., d/b/a Riggs National Bank, and Subsidiaries, Appellant v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Appellee.

United States Court of Appeals, District of Columbia Circuit.

Decided August 24, 2007.

Rehearing Denied October 22, 2007.

Attorney(s) appearing for the Case

Thomas C. Durham argued the cause for appellant. With him on the briefs were Joel V. Williamson and Russell R. Young.

Frank P. Cihlar, Attorney, U.S. Department of Justice, argued the cause for appellee. With him on the brief was Bridget M. Rowan, Attorney.

Before: ROGERS, BROWN and GRIFFITH, Circuit Judges.

Rehearing En Banc Denied October 22, 2007.

Opinion for the Court filed by Circuit Judge BROWN.

Dissenting opinion filed by Circuit Judge GRIFFITH.

BROWN, Circuit Judge:

In prior litigation, PNC Financial successfully claimed a foreign tax credit for taxes paid on its behalf in Brazil. That credit, the Internal Revenue Service argues, must be reduced by the amount of an indirect subsidy PNC received from the Brazilian government. The Tax Court...

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