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 country is reputed to be efficient, reliable, and free of corruption, and yet it has emerged as major hub for illegal
CFCs and other environmental contraband.
The purpose of both forms, one for
CFC reporting and the other for foreign partnership reporting, seems to be identical.
Incorporating science, technology and economics, the Montreal Protocol laid out timetables for every country to phase out production of
CFCs.
The volcanoes tested by Isidorov may indeed produce higher concentrations of
CFCs than the Japanese and Italian volcanoes studied, says Jordan.
5 million pounds of
CFCs but estimate that 20 million pounds illegally crossed into the United States last year.
According to the Air Conditioning and Refrigeration Institute, the number of centrifugal chillers still using
CFCs is chilling
But conversion or replacement of
CFC chillers in buildings from the White House to towering office complexes is a major challenge and will take many years.
Section 956A was enacted to create, for a
CFC that does not meet the threshold of the PFIC provisions, a greater incentive to repatriate earnings not reinvested in the
CFC's active business.
While the
CFC lookthrough rule applies to payments received by a
CFC from a related
CFC, how does the rule apply to payments made by a partnership to its more-than-50% partner that is a
CFC?
Not only has the Russian government taken little action to limit overproduction by these plants, Brack says, but the hard currency available for
CFCs on the black market poses "a major temptation in an economy undergoing such dramatic convulsions.
And we've done a conversion of one unit and are stockpiling
CFCs.
