CFCs--foreign base company income (other than FPHCI) / Lowell D. Yoder, Esq. (McDermott, Will & Emery, Chicago, Illinois), Damon M. Lyon, Esq. (McDermott Will & Emery LLP, Chicago, Illinois), David G. Noren, Esq. (McDermott Will & Emery LLP, Washington, DC).
2004
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Details
Title
CFCs--foreign base company income (other than FPHCI) / Lowell D. Yoder, Esq. (McDermott, Will & Emery, Chicago, Illinois), Damon M. Lyon, Esq. (McDermott Will & Emery LLP, Chicago, Illinois), David G. Noren, Esq. (McDermott Will & Emery LLP, Washington, DC).
Added Author
Added Corporate Author
Imprint
Arlington, VA : Tax Management Inc., [2004]-
Description
1 online resource.
Frequency
Updated irregularly
Series
Tax management portfolios ; 6240.
Formatted Contents Note
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.
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.
Summary
"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 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."
Note
Author: Lowell D. Yoder, <oct. 5, 2007>.
Formerly published in Washington, D.C., 2004-2007.
Previously published as Tax Management portfolio 928-3rd, <oct. 5, 2007>.
Formerly published in Washington, D.C., 2004-2007.
Previously published as Tax Management portfolio 928-3rd, <oct. 5, 2007>.
Bibliography, etc. Note
Includes bibliographical references.
System Details Note
Mode of access: World Wide Web.
Source of Description
Description based on contents viewed on March 22, 2019; title from description page.
Location
www
Available in Other Form
Print version: Yoder, Lowell D., 1955- CFCs--foreign base company income (other than FPHCI). Arlington, VA : Tax Management Inc., [2019]-
Linked Resources
Alternate Title
BNA Premier package.
Language
English
Record Appears in