IRS issues final foreign base company sales income regulations

US Outbound Newsalert

On December 15, 2011, the IRS issued final regulations amending that address the application of the foreign base company sales income rules to controlled foreign corporations with branches or similar establishments. The regulations finalize proposed regulations and withdraw temporary regulations issued in December 2008 with minor clarifying changes. Regulations that addressed the application of section 954(d)(1)and added the substantial contribution test were previously finalized in December 2008.



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