Court of Appeals affirms Guardian Industries case on US foreign tax credit for Luxembourg holding company The US Court of Appeals for the Federal Circuit has affirmed the decision by the US Court of Federal Claims allowing a US foreign tax credit for Luxembourg taxes paid by a Luxembourg holding company. Guardian Industries Corp. et al. v. United States (Docket No. 2006-5080, 23 February 2007). The case involved a US corporate group (Guardian Industries Corp and its subsidiaries) that conducted operations in Luxembourg through a number of Luxembourg subsidiaries owned by Guardian Industries Europe (GIE), a Luxembourg SARL. The Luxembourg...