The Resource You can be in two places at once : at 50, Subpart F embraces the modern economy

You can be in two places at once : at 50, Subpart F embraces the modern economy

Label
You can be in two places at once : at 50, Subpart F embraces the modern economy
Title
You can be in two places at once : at 50, Subpart F embraces the modern economy
Creator
Subject
Language
eng
Summary
On 10 February 2012, the IRS released Private Letter Ruling 201206003 (the LTR). In the LTR, a controlled foreign corporation (CFC) sold products that it had purchased from an unrelated corporation to related persons for use outside the CFC's country of organization. The unrelated corporation and its affiliates manufactured critical components of the products in the CFC's country of organization but manufactured other components and assembled, packaged, labeled, and shipped the products outside the CFC's country of organization. The IRS ruled that the products qualified for the same-country manufacturing exception under Code Sec. 954(d)(1)(A). Thus, the CFC's product sales did not generate foreign base company sales income under Code Sec. 954(d). The LTR is a welcome development for multinational corporations that engage in multijurisdictional manufacturing activities. The IRS accepts in the LTR that manufacturing may take place in multiple locations for purposes of Code Sec. 954(d)(1)(A). The IRS's conclusion is consistent with the legislative history of Code Sec. 954(d)(1)(A) and the subsequent case law interpreting this section. In this column, the authors address the manufacturing exceptions to foreign base company sales income, the LTR, and other fact patterns to which the LTR could apply
Citation source
In: Taxes - the tax magazine. - Chicago. - Vol. 91 (2013),
http://library.link/vocab/creatorName
  • Lipeles, S.R
  • McDonald, J.D
  • Kroll, E.S
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • private ruling
  • CFC
  • Subpart F income
  • foreign base company income
Label
You can be in two places at once : at 50, Subpart F embraces the modern economy
Instantiates
Publication
Label
You can be in two places at once : at 50, Subpart F embraces the modern economy
Publication

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