Supreme Court of the United States January 22, 1990, 88-1474 (United States v. Goodyear Tire & Rubber Co.)

Justice Marshall

delivered the opinion of the Court.

In this case, we must decide whether “accumulated profits” in the indirect tax credit provision of the Internal Revenue Code of 1954, 26 U. S. C. § 902 (1970 ed.), are to be measured in accordance with United States or foreign tax principles. We conclude that “accumulated profits” are to be measured in accordance with United States principles.