IRS applies same-country exception to CFC's sales, despite subsequent manufacturing elsewhere

March 2012


In PLR 201206003, the IRS analyzes whether the same-country manufacturing exception applies in the case where the unrelated seller of the product manufactures critical components of the product in the CFC's country of organization but the manufacture of other components and the assembly of the final product are performed by affiliates of the unrelated corporation outside of the CFC's country of incorporation.

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