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Constitutional Law Keyed to Choper
Container Corp. of America v. Franchise Tax Bd.
Citation:
463 U.S. 159 (1983)Facts
Container Corporation of America was a Delaware corporation headquartered in Illinois that manufactured custom-ordered paperboard packaging. Its operations were vertically integrated, including production of paperboard from raw materials and composition into finished products. During the tax years at issue (1963-1965), Container controlled 20 foreign subsidiaries in Latin American and European countries, with ownership percentages ranging from 66.7% to 100%. Most subsidiaries were engaged in the same business as Container in their respective local markets.
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