Cfcs Foreign Base Company Income Other Than Dphci

Author : Lowell D. Yoder
Publisher :
ISBN 13 : 9781633592575
Total Pages : pages
Book Rating : 4.5/5 (925 download)

DOWNLOAD NOW!

Download or read book CFCs--Foreign Base Company Income (other Than FPHCI) written by Lowell D. Yoder and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: "...provides a detailed analysis of two of the three categories of foreign base company income: foreign base company sales income and foreign base company services income. It also analyzes foreign base company shipping income, which was a category of foreign base company income until its repeal by the American Jobs Creation Act of 2004, and foreign base company oil related income, which was a category of foreign base company income until its repeal by "An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018." The exceptions to these categories and special rules relating thereto are also discussed in detail, including the de minimis rule, full-inclusion rule, and high-tax exception. Moreover, the application of the foreign base company income rules to partnerships with CFC partners is analyzed. The third category of foreign base company income is foreign personal holding company income (including dividends, interest, related-person factoring income, rents, royalties, annuities, commodities gains, foreign currency gains, and other income). This category of foreign base company income is discussed and analyzed in relation to the other categories of foreign base company income. Foreign personal holding company income is analyzed in detail in 6220 T.M., CFCs -- Foreign Personal Holding Company Income."