954(d) (1) as income derived by a CFC
in connection with (1) the purchase of personal property from a related person (as defined under Sec.
The country is reputed to be efficient, reliable, and free of corruption, and yet it has emerged as major hub for illegal CFCs
and other environmental contraband.
The purpose of both forms, one for CFC
reporting and the other for foreign partnership reporting, seems to be identical.
Incorporating science, technology and economics, the Montreal Protocol laid out timetables for every country to phase out production of CFCs
The volcanoes tested by Isidorov may indeed produce higher concentrations of CFCs
than the Japanese and Italian volcanoes studied, says Jordan.
5 million pounds of CFCs
but estimate that 20 million pounds illegally crossed into the United States last year.
According to the Air Conditioning and Refrigeration Institute, the number of centrifugal chillers still using CFCs
But conversion or replacement of CFC
chillers in buildings from the White House to towering office complexes is a major challenge and will take many years.
Section 956A was enacted to create, for a CFC
that does not meet the threshold of the PFIC provisions, a greater incentive to repatriate earnings not reinvested in the CFC
's active business.
While the CFC
lookthrough rule applies to payments received by a CFC
from a related CFC
, how does the rule apply to payments made by a partnership to its more-than-50% partner that is a CFC
Not only has the Russian government taken little action to limit overproduction by these plants, Brack says, but the hard currency available for CFCs
on the black market poses "a major temptation in an economy undergoing such dramatic convulsions.
And we've done a conversion of one unit and are stockpiling CFCs