International Tax

CFCs — Foreign Base Company Income (Other than FPHCI) (Portfolio 6240)

  • This Portfolio focuses on the provisions of §954 other than those pertaining to foreign personal holding company income.

Description

This Portfolio, CFCs — Foreign Base Company Income (Other than FPHCI) focuses on the provisions of §954 other than those pertaining to foreign personal holding company income. It provides a detailed analysis of three of the four categories of foreign base company income: (1) foreign base company sales income, (2) foreign base company services income, and (3) foreign base company oil related income. It also analyzes foreign base company shipping income, which was a category of foreign base company income until its repeal by the American Jobs Creation Act of 2004.

The exceptions to these categories and special rules relating thereto are also discussed in detail, including the de minimis rule, full inclusion rule, and high-tax exception. Moreover, the application of the foreign base company income rules to partnerships with CFC partners is analyzed. The fourth category of foreign base company income is foreign personal holding company income (including dividends, interest, related person factoring income, rents, royalties, annuities, commodities gains, foreign currency gains, and other income), and is analyzed in detail in 6220 T.M., CFCs — Foreign Personal Holding Company Income.

Table of Contents

I. Introduction
II. Legislative History
III. Overview of Foreign Base Company Income Regime
IV. Character of Items of Foreign Base Company Income
V. Definition of Related Person
VI. Foreign Personal Holding Company Income
VII. Foreign Base Company Sales Income
VIII. Foreign Base Company Services Income
IX. Foreign Base Company Shipping Income — Pre-2004
X. Foreign Base Company Oil Related Income
XI. Foreign Base Company Income Special Rules and Exceptions
XII. Controlled Foreign Corporation Owned Partnerships

Lowell Yoder
Partner
McDermott Will & Emery LLP
Damon-Lyon
Damon Lyon
Partner
McDermott Will & Emery LLP
David-Noren
David Noren
Partner
McDermott Will & Emery LLP
https://pillsbank.net

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