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Foreign base company income |
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Foreign base company income A category of Subpart F income that includes foreign holding company income and foreign base company saless and service income. How to thank TFD for its existence? Tell a friend about us, add a link to this page, add the site to iGoogle, or visit webmaster's page for free fun content. |
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| 13) Yet another technique discussed by the study is the ability to use dual resident corporations to avoid the application of the foreign base company income rules. 954(a) defines foreign base company income to include (1) most types of passive income, (2) sales income for which neither manufacturing nor sales occur within the CFC's country, (3) many types of services income for which the services are performed outside the CFC'S country for a related party, (4) most types of shipping income (unless the shipping activity begins and ends in the CFC's country) and (5) certain types of oil-related income. De Minimis Rule for Subpart F Income: Section 954(b)(3) of the Code provides that no part of a CFC's gross income is treated as foreign base company income (FBCI) if its FBCI and insurance income for the year is less than the smaller of(i) five percent of its gross income for the year or (ii) $1 million. |
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