The webinar will provide an overview of the subpart F foreign base company sales income rules, including a description of the general rule and the types of transactions to which it applies, followed by a discussion of the various exceptions to the rule. The webinar will then focus on deferral planning through contract manufacturing arrangements, including the “substantial contribution test” and the “branch” rules. I. Overview of different types of manufacturing arrangements:
Attendees will gain an in-depth understanding of the subpart F foreign base company sales income (“FBCSI”)/section 954(d) rules, including:
As a special offer, all webinar registrants may apply a $200 discount to the upcoming two-day CITE conference, U.S. Tax Planning for CFCs Under Subpart F on April 25 & 26 in Chicago, IL. More details will be provided following the webinar.
Rafic Barrage, Meyer Brown LLP