United States v. Phellis

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United States v. Phellis
Seal of the United States Supreme Court.svg
Argued October 11, 1921
Decided November 21, 1921
Full case nameUnited States v. C. W. Phellis
Citations 257 U.S. 156 ( more )
42 S.Ct. 63; 66 L. Ed. 180; 1921 U.S. LEXIS 1328
Holding
Shares in a subsidiary corporation issued to stockholders in the parent corporation are taxable as income.
Court membership
Chief Justice
William H. Taft
Associate Justices
Joseph McKenna  · Oliver W. Holmes Jr.
William R. Day  · Willis Van Devanter
Mahlon Pitney  · James C. McReynolds
Louis Brandeis  · John H. Clarke
Case opinions
Majority Pitney, joined by Taft, McKenna, Holmes, Day, Brandeis, Clarke
Dissent McReynolds, joined by Van Devanter

United States v. Phellis, 257 U.S. 156 (1921), was a decision by the United States Supreme Court, which held that shares in a subsidiary corporation issued to stockholders in the parent corporation were taxable as income.

Share (finance) single unit of ownership in a corporation, mutual fund, or any other organization

In financial markets, a share is a unit used as mutual funds, limited partnerships, and real estate investment trusts. The owner of shares in the corporation/company is a shareholder of the corporation. A share is an indivisible unit of capital, expressing the ownership relationship between the company and the shareholder. The denominated value of a share is its face value, and the total of the face value of issued shares represent the capital of a company, which may not reflect the market value of those shares.

A subsidiary, subsidiary company or daughter company is a company that is owned or controlled by another company, which is called the parent company, parent, or holding company. The subsidiary can be a company, corporation, or limited liability company. In some cases it is a government or state-owned enterprise. In some cases, particularly in the music and book publishing industries, subsidiaries are referred to as imprints.

A shareholder is an individual or institution, including a corporation, that legally owns one or more shares of stock in a public or private corporation. Shareholders may be referred to as members of a corporation. Legally, a person is not a shareholder in a corporation until their name and other details are entered in the corporation‘s register of shareholders or members. A beneficial shareholder is the person that has the economic benefit of ownership of the shares, while a nominee shareholder is the person who is on the corporation’s register as the owner while being in fact acting for the benefit and at the direction of the beneficiary, whether disclosed or not.

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