Tax classification of retained earnings and unremitted foreign income as reserves upheld where no real distinction was shown.

Amounts described as "retained earnings" and "unremitted foreign income" were treated as having the same character for tax purposes and were accepted as reserves. The Court noted that the issue was already covered by an earlier decision, and the record before the Tribunal and High Court did not support any meaningful distinction between the two labels. As a result, the amounts shown under either description were correctly classified as reserves, and the challenge failed.

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Issues: Whether the amounts described as "retained earnings" and "unremitted foreign income" were to be treated as reserves for tax purposes.

Analysis: The question was held to be covered by an earlier decision of the Court. The expressions "retained earnings" and "unremitted foreign income" were found to be used in the same sense, and the amounts shown under either description were accepted as having the same character. The record before the Tribunal and the High Court did not support the suggested distinction between the two labels.

Conclusion: The amounts were correctly treated as reserves, and the appeal failed.

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