To summarize, US1's and US2's outside basis totals $10, which corresponds to the PTI distribution from
CFC that remains to be distributed to the partners.
Thanks to the forces of economic globalization, contraband including
CFCs, endangered species, and toxic waste is flowing through national borders that are disturbingly porous.
In recent years
CFC has developed a variety of social ministries that work toward sustainable community development, building homes, establishing schools, and teaching catechism, as well as sending medical missionaries to needy areas, especially in the Philippines.
But what illegal
CFCs lack in cultural cachet, they make up for in volume and profitability.
At this stage of the phase-out, many experts expected that
CFCs would no longer be in use.
A key component of the program is
CFC Facts, a newsletter that will give retailers up-to-date information on both technological and legislative developments on the
CFC issue.
CFCs may also trap heat in the atmosphere and thus contribute to the global warming trend (greenhouse effect).
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 higher
CFC concentrations seen in earlier studies "could have been a methods issue, or it could be that the volcanoes were different," Butler says.
For purposes of determining foreign base company sales (FBCS) income, where a controlled foreign corporation (
CFC) carries on activities through a branch outside the country of the
CFC's incorporation and the branch is effectively treated as a separate subsidiary, section 954(d)(2) provides that the income attributable to the branch's activities will be treated as income derived from a wholly owned subsidiary for purposes of computing the FBCS income of the
CFC.
And to
CFC smugglers, we say: We're going to find you.
