With respect to the application of the proposed regulations to foreign sales corporations
(FSCs) and domestic international sales corporations (DISCS), we recommend that the final regulations reflect the decision in St.
Interest-charge domestic international sales corporations (IC-DISCs)and foreign sales corporations
(FSCs), S corporations, personal service corporations, minority shareholders in controlled foreign corporations or foreign personal holding companies, certain passive foreign investment companies (PFICs) and certain shareholders of PFICs cannot use the expedited procedure.
1] Since income tax returns for Foreign Sales Corporations
were not a part of the sample used for the statistics, this income category is not included.
The tax release on Wisconsin's treatment of Foreign Sales Corporations
FSCs) is scheduled to be included in the January 1995 Wisconsin Tax Bulletin.
Under normal circumstances, foreign sales corporations
(FSCs) should pay regular annual dividends to their parent corporations.
Under the boycott provisions, penalties include a reduction of foreign tax credits, an increase in taxable income for Controlled Foreign Corporations under subpart F, and a reduction in benefits otherwise allowed regarding Foreign Sales Corporations
(FSC's) and Interest-Charge Domestic International Sales Corporation (ICDISC's), as applicable.
Department of the Treasury, the chairs of the congressional tax-writing committees, and the staff of the Joint Committee on Taxation on two issues relating to foreign sales corporations
(FSCS): (i) the requirement for Joint Committee review of FSC refund claims; and (ii) the effect of the estimated tax provisions on FSCS and their related suppliers.
Under the current PFIC rules, it is unclear whether those rules apply to foreign sales corporations
(FSCs) whose passive income is already subject to current U.
Foreign Sales Corporations
(FSC's) filed 4,200 income tax returns for Tax Year 2000.
Comments on Application of Estimated Tax Rules to Foreign Sales Corporations
We believe that the diversity and professional training of our members enable us to bring an important, balanced, and practical perspective to the issues raised by the proposed regulations relating to adjusted current earnings and the temporary regulations relating to foreign sales corporations
On March 2, 1990, Tax Executives Institute filed the following comments with the Internal Revenue Service on various issues relating to foreign sales corporations