Subpart F

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.
References in periodicals archive ?
951-964, certain income of a controlled foreign corporation (CFC), referred to as Subpart F income, is included in the income of its U.
Rather than imposing a complex subpart F analysis on the active income of all business operations, the original 1962 legislation provided a substantial de minimis rule that excluded from subpart F amounts equal to up to 30 percent of a CFC's gross income.
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.
The Revenue Reconciliation Bill of 1995, if enacted, would clarify the treatment of Subpart F income earned by a controlled foreign corporation (CFC) in which a tax-exempt organization is a U.
Controlled foreign corporations (CFCs), as defined in section 957 of the Internal Revenue Code, that have Subpart F income.
S persons, each of whom owns at least 10 percent directly or indirectly), or a Foreign Personal Holding Company (FPHCO), some or all of the deemed asset sale gain could be Subpart F or FPHCO income.
Commissioner, ruling that a controlled foreign corporation's (CFC) distributive share of income from a foreign partnership be treated as if it was directly earned by the CFC and, therefore, characterized as subpart F income.
Illinois Department of Revenue, the Illinois Appellate Court considered the characterization of Subpart F income for state law purposes.
959(c)(2) account, from current- or prior-year subpart F income inclusions and Sec.
The Brown Group regulations--concerned with whether the "entity" or "aggregate" theory of partnership tax applies in the context of Subpart F rules--was also discussed.