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Subpart F

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Subpart F
Special category of foreign-source "unearned" income that is currently taxed by the IRS whether or not it is remitted to the US

Subpart F
In U.S. taxation, income from foreign subsidiaries of American companies. Income under subpart F is subject to taxation even if it is not repatriated into the United States. Interestingly, subpart F income also includes the amount of money the subsidiary paid in bribes to foreign officials.


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In the context of the international sales of goods, prior to the creation of the Transfer Pricing and Subpart F rules, a taxpayer could create a subsidiary corporation in a foreign low-tax jurisdiction and then sell goods to that foreign subsidiary at a price equal to or slightly above cost, triggering a small amount of U.
Introduction On February 27, 2008, the Internal Revenue Service issued the long-awaited proposed regulations dealing with whether contract manufacturing arrangements entered into by a controlled foreign corporation (CFC) will constitute manufacturing for subpart F purposes.
the Commissioner that assembly operations performed by two foreign subsidiaries of Bausch & Lomb constituted "manufacturing" for purposes of the subpart F provisions, and income from the sale of the company's assembled goods was not considered subpart F income.
 
 
 
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