The Resource The application of Subpart F to a distributor principal

The application of Subpart F to a distributor principal

Label
The application of Subpart F to a distributor principal
Title
The application of Subpart F to a distributor principal
Creator
Subject
Language
eng
Summary
Sales income derived by a controlled foreign corporation (CFC) that does not purchase property from, nor sell property to, a related person generally is not Subpart F income. Under certain circumstances, however, a sales branch rule can apply to treat a portion of the sales income as Subpart F income (i.e., foreign base company sales income, "FBCSI"). After discussing the application of the general FBCSI rule to distributor principals, the author describes certain rules that govern the application of the sales branch rule
Citation source
In: Tax management international journal. - Arlington. - Vol. 40 (2011),
http://library.link/vocab/creatorName
Yoder, L.D
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • CFC
  • Subpart F income
  • branch rule
  • foreign base company income
Label
The application of Subpart F to a distributor principal
Instantiates
Publication
Label
The application of Subpart F to a distributor principal
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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