Both
CFC 1 and
CFC 3 apply the Section 163(j) limitation to business interest expense (BIE) as if they were standalone U.S.
(32) For purposes of these rules, the proposed regulations use the statutory formula to allocate the GILTI inclusion amount back to individual
CFCs, with tested income taken into account in determining a U.S.
For Tax Year 2008,
CFCs engaged in finance, insurance, real estate, and rental and leasing held 46.4 percent of all assets while generating only 11.6 percent of the total receipts and 8.5 percent of the E&P (less deficit) before income taxes reported by all
CFCs.
A branch is treated as a manufacturing branch where a
CFC carries on manufacturing activities by or through a branch located outside the
CFC's country of incorporation and the remainder of the
CFC purchases or sells the personal property.
Luege said the move to halt production of
CFCs demonstrates Mexico's commitment to international conventions to protect the environment.
In the 1970s, scientists first discovered that
CFCs and other chemicals could damage the Earth's protective ozone layer, which shields life on Earth from the harmful effects of ultraviolet (UV) radiation.
The project, along with similar ones undertaken by the World Bank in China and Russia, will help phase out more than 80% of the remaining global
CFC production.
Cheap, foreign-made
CFCs provide an easy "fix" for consumers reliant on outdated technologies.
The seven Russian
CFC factories named by the UN environment watchdog are believed to be the principle source of the estimated 30,000 tonnes of
CFCs illegally traded in the Western world.
Recycled
CFCs are legal, Bocksaid,but the smuggling activity has made recycling and cleaning of used
CFCs unprofitable.
The major manufacturers had voluntarily agreed to phase-out the most widely used
CFCs, those known as R-11 and R-12, long before the legal phaseout date.
Ray went on to insist that there was little likelihood that freons (chlorofluoro-carbons, or
CFCs for short) would reach the stratosphere.
