If the effective tax rate in the country where the sales are executed is less than 90% of, and at least five percentage points less than, the effective tax rate in the country where the manufacturing branch is located, then the manufacturing branch is treated as a separate, wholly owned subsidiary of the CFC
Thanks to the forces of economic globalization, contraband including CFCs
, endangered species, and toxic waste is flowing through national borders that are disturbingly porous.
In recent years CFC
has developed a variety of social ministries that work toward sustainable community development, building homes, establishing schools, and teaching catechism, as well as sending medical missionaries to needy areas, especially in the Philippines.
But what illegal CFCs
lack in cultural cachet, they make up for in volume and profitability.
5 million pounds of CFCs
but estimate that 20 million pounds illegally crossed into the United States last year.
At this stage of the phase-out, many experts expected that CFCs
would no longer be in use.
If rents or royalties are received or accrued from a partnership with one or more partners that are CFCs
, such rents or royalties will be treated as received or accrued from a CFC
for purposes of the CFC
lookthrough rule of Sec.
The higher CFC
concentrations seen in earlier studies "could have been a methods issue, or it could be that the volcanoes were different," Butler says.
954-3(b)(3) confirms that the branch rule applies only to treat the branch of the CFC
"parent" as a discrete CFC
for purposes of determining FBCS income.
While most modern countries including the United States have adopted the Montreal and Helsinki protocols to help end the depletion of the ozone layer, some Third World countries are not being as vigilant in their CFC
For the fiscal year ended May 31, 1994, CFC
reported a times interest earned ratio (TIER) of 1.
A second deferral-limiting provision applies when a CFC
invests earnings in certain types of U.