The Resource No Subpart F income if no related party purchase or sale of products

No Subpart F income if no related party purchase or sale of products

Label
No Subpart F income if no related party purchase or sale of products
Title
No Subpart F income if no related party purchase or sale of products
Creator
Subject
Language
eng
Summary
Income derived by a controlled foreign corporation (CFC) from selling products, as a general rule, is not Subpart F income. Such income is Subpart F income only if it falls within the definition of foreign base company sales income (FBCSI) under Code Sec. 954(d). Code Sec. 954(d)(1) provides that income from the purchase and sale of property is FBCSI only if it is derived by a CFC in connection with either: (1) the purchase of personal property from a related person and its sale to any person, or (2) the purchase of personal property from any person and its sale to a related person. Therefore, FBCSI does not include income derived by a CFC from selling products where the CFC does not purchase the products from a related person, nor sell the products to a related person. Taxpayers often arrange their global supply chains to minimize the instances when products sold by a CFC are purchased from related persons or sold to related persons. The courts have uniformly upheld, and the government has recognized, such planning structures
Citation source
In: International tax journal. - Chicago. - Vol. 40 (2014), no. 4 (July-August) ; p. 3-4
http://library.link/vocab/creatorName
Yoder, L.D
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • Subpart F income
  • CFC
Label
No Subpart F income if no related party purchase or sale of products
Instantiates
Publication
Label
No Subpart F income if no related party purchase or sale of products
Publication

Library Locations

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      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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