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
may also trap heat in the atmosphere and thus contribute to the global warming trend (greenhouse effect).
Additional information about CFC
is available on CFC
's Web site at www.
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.