Siemens Medical Solutions USA, Inc. and Consolidated Subsidiaries

Summary

The Tax Court held that Siemens was entitled to the full dividends-received deduction for its foreign-source dividend under section 245A. The court held that the Extraordinary Disposition Rules could not limit that deduction because they conflicted with the statute's clear text and exceeded Treasury's delegated authority. The court granted Siemens's motion for summary judgment and denied the Commissioner's cross-motion.