What people are saying - Write a review
We haven't found any reviews in the usual places.
Introductory Remarks and Definitions
Subpart F Income
Exclusion from Gross Income
11 other sections not shown
Other editions - View all
50 percent acquired foreign corporation acquisition advance ruling amount apply assets avoidance of Federal capital gains CFC's controlled foreign corporation described in section developed country corporation dividend domestic corporation earnings and profits election exchange described exclusion favorable ruling Federal income tax foreign base company foreign cor foreign personal holding foreign subsidiary foreign tax credit gross income guidelines Internal Revenue Code invested in U.S. IRC Section issued ldcc less developed country lower tier corporation minimum distribution Netherlands Antilles ownership parent personal holding company poration principal purposes Proc provisions reorganization Revenue Procedure ruling under section section 367 Section l248 shares source income stock or securities Subpart F income tax avoidance tax treaties taxation taxpayer tion toll charge trade or business transaction transfer transferor treaty U. S. property U.S. person U.S. shareholder U.S. tax United States person voting power WHTC