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| Material Type: | Updating loose-leaf |
|---|---|
| Document Type: | Continually Updated Resource |
| All Authors / Contributors: |
Lowell D Yoder; Tax Management Inc. |
| OCLC Number: | 56720008 |
| Notes: | "This portfolio, together with 927 T.M., "CFCs--Foreign personal holding company income," revises and supersedes 928-2nd T.M., "Subpart F--Foreign base company income." |
| Description: | v. (loose-leaf) ; 28 cm. |
| Contents: | Detailed analysis. Introduction -- Legislative history -- Overview -- Character of items of income -- Definition of related person -- Foreign personal holding company income -- Foreign base company sales income -- Foreign base company services income -- Foreign base company shipping income -- Foreign base company oil related income -- FBCI special rules and exceptions -- CFC owned partnerships -- Table of worksheets. |
| Series Title: | Tax management portfolios, 928-3rd. |
| Other Titles: | Foreign base company income (other than FPHCI) Controlled foreign companies--foreign base company income (other than FPHCI) CFCs--Foreign base company income (other than foreign personal holding company income) |
| Responsibility: | revision by Lowell D. Yoder. |
Abstract:
" ... focuses on the provisions of [section] 954 other than those pertaining to foreign personal holding company income. Section 954 forms the functional heart of "Subpart F," which relates to U.S. taxation of shareholders of controlled foreign corporations ("CFCs")."
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