shareholder to have Subpart F
income instead of GILTI.
In the third and final course of the series, FHWA Planning and Research Grants: The Uniform Guidance (2 CFR Part 200)--Part 2 (course number 151059), learners explore the last two subparts of the Uniform Guidance: subpart E on cost principles and subpart F
on audit requirements.
951-964, certain income of a controlled foreign corporation (CFC), referred to as Subpart F
income, is included in the income of its U.S.
Under subpart F
of the Internal Revenue Code, 10 percent of U.S.
the Commissioner that assembly operations performed by two foreign subsidiaries of Bausch & Lomb constituted "manufacturing" for purposes of the subpart F
provisions, and income from the sale of the company's assembled goods was not considered subpart F
The Revenue Reconciliation Bill of 1995, if enacted, would clarify the treatment of Subpart F
income earned by a controlled foreign corporation (CFC) in which a tax-exempt organization is a U.S.
Because subpart F
income has been included in the U.S.
These provisions, together with the treatment of the European Union as one country for Subpart F
purposes, will effect meaningful reform.
If the foreign target is a Controlled Foreign Corporation, or CFC (more than 50 percent owned by U.S persons, each of whom owns at least 10 percent directly or indirectly), or a Foreign Personal Holding Company (FPHCO), some or all of the deemed asset sale gain could be Subpart F
or FPHCO income.
Commissioner, ruling that a controlled foreign corporation's (CFC) distributive share of income from a foreign partnership be treated as if it was directly earned by the CFC and, therefore, characterized as subpart F
Illinois Department of Revenue, the Illinois Appellate Court considered the characterization of Subpart F
income for state law purposes.
959(c)(2) account, from current- or prior-year subpart F
income inclusions and Sec.