Examples of Subpart F Income in a sentence
Repeal of Inclusion Based on Withdrawal of Previously Excluded Subpart F Income from Qualified Investment (sec.
TheC.F.C. rules are designed to discourage the retention of earnings at the level of theC.F.C. Instead of deferral of tax, the C.F.C. rules force a U.S. shareholder owning 10% or more of the voting stock to include in a U.S. tax return the earnings generated from Subpart F Income, typically Foreign Base Company Sales Income and Foreign Personal Holding Company Income.
Repeal of Treatment of Foreign Base Com- pany Oil Related Income as Subpart F Income (sec.
Gross Income Taken into Account in Determining Subpart F Income Another item excluded from gross tested income is gross income taken into account in determining a corporation’s subpart F income.
Residency issues; source of income; tax havens; unilateral relief and Double Tax Avoidance; transfer pricing; international merger and acquisitions; impact of tax on GATT 94, WTO, anti dumping processing; the subpart F Regime : definition of CFC, Subpart F Income and Operating Rules.