CFCs--foreign base company income (other than FPHCI) [electronic resource] / Lowell D. Yoder, Esq. (McDermott, Will and Emery, Chicago, Illinois), Damon M. Lyon, Esq. (McDermott Will and Emery LLP, Chicago, Illinois), David G. Noren, Esq. (McDermott Will and Emery LLP, Washington, DC).
"This Portfolio 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 unti...
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Law Students, Faculty, and Staff (via Bloomberg Law) |
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| Main Authors: | , , |
| Other title: | Foreign base company income (other than FPHCI) Controlled foreign companies--foreign base company income (other than FPHCI) CFCs--Foreign base company income (other than foreign personal holding company income) Bloomberg Law online Bloomberg Law online. |
| Format: | Electronic Website |
| Language: | English |
| Published: |
Arlington, VA :
Tax Management Incorporated,
[2004]-
|
| Series: | Tax management portfolios ;
6240. |
| Subjects: |
Table of Contents:
- Detailed Analysis. Introduction
- Legislative History
- Overview of Foreign Base Company Income Regime
- Character of Items of Foreign Base Company Income
- Definition of Related Person
- Foreign Personal Holding Company Income
- Foreign Base Company Sales Income
- Foreign Base Company Services Income
- Foreign Base Company Shipping Income--Pre-2004
- Foreign Base Company Oil Related Income
- Foreign Base Company Income Special Rules and Exceptions
- Controlled Foreign Corporation Owned Partnerships
- Working papers.