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abroad accumulated DISC income adjusted basis allowed apply apportioned attributable combined taxable income commission consent controlled foreign corporation controlled group December 31 deductions deemed distribution defined in section described in paragraph determined DISC or former dividend dividends received earnings and profits election example export promotion expenses export property export sales export trade corporation filed foreign corporation foreign currency foreign income taxes foreign tax credit former DISC gross receipts income from sources Internal Revenue Code Internal Revenue Service loss manufacturer's Marginal Costing paid previously taxed income producer's loans products sold proposed Reg Proposed Treasury Decision Puerto Rico purchaser pursuant qualified export assets qualified export receipts related supplier respect rules Safe-Haven Method sale or lease section 994 selling shareholders shares statutory grouping subdivision taxpayer tion transaction transfer price treated U.S. corporation U.S. dollars U.S. income tax U.S. manufacturer U.S. possession U.S. tax United Western Hemisphere WHTC