2013-09-05
For the 32nd week of 2013, the IRS published the following Private Letter Ruling relating to international taxation.
PLR 201332007: Commissions received by disregarded entity of CFC related to sales of products was not foreign base company sales income ("FBCSI") because the disregarded entity made a substantial contribution to the manufacture of the property. Code §954(d). For prior coverage of this PLR, see IRS Rules Commission Income From Sales is Not FBCSIRules
DISCLAIMER
The posts on this blog have not been verified for accuracy. You should consult an attorney for legal advice regarding your own situation. These posts are not updated for changes in the tax laws. Further, these posts should not be relied upon for any purpose whatsoever.
65 Main Street, Centerbrook, Connecticut, 06409 USA | Ph: (860) 767-4975 | Fax: (860) 756-0954
Copyright © 2004 – 2025, Andrew Mitchel LLC. All rights reserved.