Stats., sections 921 and 927 of the Internal Revenue Code (IRC) (relating to foreign sales corporations
) are excluded in computing Wisconsin income.
The European Community (EC) requested a consultation with the United States on November 18, 1997, to discuss sections 921-927 of the United States Internal Revenue Code (IRC) and related measures establishing special tax treatment for foreign sales corporations
. (6) Specifically, the EC alleged that the IRC provided tax exemptions on income related to exports to U.S.
By exporting goods through foreign sales corporations
(FSCs), for example, corporations can reduce their taxes on exports by about 5% of the taxable profit.
To qualify for the 15% exemption, the FSC must satisfy several rules regarding its organization, management and "economic processes." In essence, the foreign sales corporation
must indeed be "foreign." It must be incorporated, have its main office and keep its records outside the U.S.(4) Further requirements in regard to the management and operation of the FSC are designed to insure that there are substantial contacts with and activities in its non-U.S.
We hope that through the increased use of Foreign Sales Corporations
, whether shared or not, Utah exporters will profit even to a greater degree from exporting."
Foreign Sales Corporation
(FSC) regime in the World Trade Organization (WTO).
Since 2000, the European Union (EU) has been successful twice in having the World Trade Organization (WTO) declare that export-related benefits (Foreign Sales Corporation
and Extraterritorial Income rules) the U.S.
Committee chairman Bill Thomas (R-CA) indicated that the bill could be attached to the Foreign Sales Corporation
and Extraterritorial Investment Act (FSC-ETI) pending before the full House.
The FSC Repeal and Extraterritorial Income Exclusion Act of 2000 repealed the foreign sales corporation
rules and replaced them with new tax rules regarding foreign sales.
Foreign Sales Corporation
. The second corporate form available to U.S.
IT-MAP is made up of four modular components: International Electronic Tax Package (I-ETP) software for collecting, classifying and adjusting financial accounts; Foreign Tax Credit (FTC) software for calculating foreign tax credit and generating Form 1118; Controlled Foreign Corporation (CFC) software for analyzing earnings and profits, as well as Subpart F income and generating Form 547 1; and Foreign Sales Corporation
(FSC) software for handling grouping and pricing alternatives and calculations, as well as generating Form 1120-FSC.
Foreign sales corporation
(FSC)--A foreign sales corporation
was a company incorporated abroad and controlled by a "U.S.