CFCs — Foreign Base Company Income (Other than FPHCI) (Portfolio 6240)

Tax Management Portfolio, CFCs — Foreign Base Company Income (Other than FPHCI), focuses on the provisions of §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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Description

This Portfolio provides a detailed analysis of three of the four categories of foreign base company income: (1) foreign base company sales income, (2) foreign base company services income, and (3) foreign base company oil related income. It also analyzes foreign base company shipping income, which was a category of foreign base company income until its repeal by the American Jobs Creation Act of 2004. The exceptions to these categories and special rules relating thereto are also discussed in detail, including the de minimis rule, full inclusion rule, and high-tax exception. Moreover, the application of the foreign base company income rules to partnerships with CFC partners is analyzed. The fourth category of foreign base company income is foreign personal holding company income (including dividends, interest, related person factoring income, rents, royalties, annuities, commodities gains, foreign currency gains, and other income), and is analyzed in detail in 6220 T.M., CFCs — Foreign Personal Holding Company Income.

Authors

Lowell D. Yoder

Lowell D. Yoder, B.A. (1979, with highest distinction) and J.D. (1982, magna cum laude), University of Illinois; Order of the Coif; Law Review Editor; Law Clerk, The Honorable James M. Sprouse, Federal Court of Appeals for the Fourth Circuit; frequent lecturer and author of numerous articles on international taxation; Fellow of the American College of Tax Counsel; Editor-in-Chief of the Journal of Taxation of Global Transactions; Counsel Member of the International Fiscal Association; member of the Tax Management International Journal Advisory Board, member of Editorial Board of the Journal of International Taxation, and member of the University of Chicago Law School's Federal Tax Conference Planning Committee; Adjunct Professor of Law at University of Illinois Law School and Chicago-Kent College of Law, and Assisting Practitioner for the Graduate Tax Program of Northwestern University School of Law.

Damon M. Lyon, Esq.

Damon M. Lyon, B.A. (1997, with highest honors), Michigan State University; J.D. (2000, cum laude), University of Michigan Law School; frequent speaker on international tax topics; author of articles on international taxation.

David G. Noren, Esq.

David G. Noren, A.B. (1993, with distinction, Phi Beta Kappa), Stanford University; J.D. (1996, magna cum laude, Harvard Law Review), Harvard Law School; Legislation Counsel to the Joint Committee on Taxation, U.S. Congress (2001–2006); Acting Assistant Professor of Law, New York University School of Law (1999–2001); Associate, Baker & McKenzie, Chicago (1996–1999); frequent speaker and writer on international tax topics.

Table of Contents

Detailed Analysis
I. Introduction
II. Legislative History
Introductory Material
A. Revenue Act of 1962
1. In General
2. Types of Income
3. Special Rules and Exceptions
B. Tax Reform Act of 1969
1. Overview
2. “Not-Formed-or-Availed-of” Exception
C. Tax Reduction Act of 1975
1. Foreign Base Company Shipping Income
2. Exception for Agricultural Commodities
3. Reduction of De Minimis Exception Threshold
D. Tax Reform Act of 1976
1. Overview
2. Shipping Income Exception
E. Tax Equity and Fiscal Responsibility Act of 1982
1. Overview
2. Foreign Oil Related Income
F. Tax Reform Act of 1984
1. Overview
2. Factoring Income
3. Foreign Base Company Oil Related Income
G. Tax Reform Act of 1986
1. Expansion of Types of Foreign Personal Holding Company Income
a. Overview
b. Gains from Certain Property
c. Income from Commodities Transactions
d. Foreign Currency Gains
e. Banking and Insurance Income
f. Income Equivalent to Interest
g. Related Person Exceptions
(1) FPHCI Rules
(2) Related Person Factoring Income
2. Foreign Base Company Shipping Income
a. Repeal of Exclusion for Reinvested Shipping Income
b. Space or Ocean Income
3. Contraction of Exceptions and Limitations to Foreign Base Company Income
a. High-Tax Exception
b. De Minimis Exception
c. Full-Inclusion Rule
4. Expansion of Definition of Related Person
H. Technical and Miscellaneous Revenue Act of 1988
1. Definition of Related Person
2. Same-Country Exceptions to Foreign Personal Holding Company Income
3. Gains as FPHCI
I. Revenue Reconciliation Act of 1989
J. Omnibus Budget Reconciliation Act of 1993
1. Overview
2. Limitation on Same-Country Dividend Exception
3. Expansion of Foreign Base Company Sales Income
4. Foreign Personal Holding Company Income Priority Rule
a. Foreign Base Company Shipping Income
b. Foreign Base Company Oil Related Income
K. Taxpayer Relief Act of 1997
1. Overview
2. Expansion of Foreign Personal Holding Income
3. Dealer Exception
4. Active Financing and Insurance Exception
5. Dispositions of Lower-Tier CFCs
a. Application of Principles of §1248 to Gain from Stock Sales by Controlled Foreign Corporations
b. Basis Adjustments for Lower-Tier Controlled Foreign Corporations
L. The Tax and Trade Relief Extension Act of 1998
M. The Tax Relief Extension Act of 1999
N. The Job Creation and Worker Assistance Act of 2002
O. American Jobs Creation Act of 2004
P. Tax Increase Prevention and Reconciliation Act of 2005
Q. Tax Extenders and Alternative Minimum Tax Relief Act of 2008
R. Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010
S. American Taxpayer Relief Act of 2012
T. Tax Increase Prevention Act of 2014
U. Protecting Americans from Tax Hikes Act of 2015
V. 2017 Tax Act
1. Overview
2. Definitions of U.S. Shareholder and CFC
3. Subpart F Inclusions
4. Global Intangible Low-Taxed Income Inclusion
5. Foreign Derived Intangible Income and Global Intangible Low-Taxed Income Deduction
6. Dividends Received from Controlled Foreign Corporations, Taxation of Historic Earnings and the Participation Exemption System
7. Investments in U.S. Property
8. Sale of a Controlled Foreign Corporation
a. Rules Relating to Sales and Exchanges of Stock in a Controlled Foreign Corporation
b. Sales by a Controlled Foreign Corporation of a Lower Tier Controlled Foreign Corporation
c. Basis in Specified 10-Percent Owned Foreign Corporation
d. Asset Transfers
9. Base Erosion and Anti-Abuse Tax
10. Other Provisions of the 2017 Tax Act
III. Overview of Foreign Base Company Income Regime
A. Categories of Foreign Base Company Income
B. Full-Inclusion Rule
C. Foreign Base Company Income Exceptions
D. Net Foreign Base Company Income
IV. Character of Items of Foreign Base Company Income
A. In General
B. Substance of the Transaction
C. Different Types of Income from a Single Transaction
1. General Segregation Rule
2. Integrated Transactions — Predominant Character Test
D. Coordination of Categories of Foreign Base Company Income
1. Priority Rules
2. Application of Exceptions
E. Partnership Income
V. Definition of Related Person
A. In General
B. Control Requirement
1. Individuals
2. Other Persons
C. Control Threshold
1. In General
2. Related Corporations
3. Related Partnerships
4. Related Trusts and Estates
5. Amendments to the Definition of Related Person by the Tax Reform Act of 1986
6. Direct, Indirect, and Constructive Ownership
VI. Foreign Personal Holding Company Income
A. Overview
1. In General
2. Categories of Foreign Personal Holding Company Income
3. Exceptions to Foreign Personal Holding Company Income
B. Dividends, Interest, Rents, Royalties, and Annuities
1. Dividends
a. Same-Country Exception for Dividends
b. Temporary Look-Through Exception — §954(c)(6)
c. Other Exclusions and Exceptions
2. Interest
a. Related-Person Factoring Income
b. Exclusions and Exceptions
3. Rents
a. Active Business Exception for Rents — §954(c)(2)(A)
b. Same-Country Exception for Rents — §954(c)(3)(A)(ii)
c. Temporary Look-Through Exception — §954(c)(6)
4. Royalties
a. Active Business Exception for Royalties — §954(c)(2)(A)
b. Same-Country Exception for Royalties — §954(c)(3)(A)(ii)
c. Temporary Look-Through Exception — §954(c)(6)
5. Annuities
C. Gains from Certain Property Transactions
D. Gains from Commodities Transactions
E. Foreign Currency Gains
F. Income Equivalent to Interest
G. Income from Notional Principal Contracts
H. Payments in Lieu of Dividends — Income from Stock Lending Transactions
I. Contracts to Furnish Personal Services
J. Special Exceptions
1. Exception for Active Banking, Financing, or Securities Income
2. Exception for Active Insurance Income
3. Exceptions for Dealers
VII. Foreign Base Company Sales Income
A. In General
1. Overview
2. Legislative Background
a. The Revenue Act of 1962
b. Post-1962 Amendments
3. Overview of Basic Rules
4. Partnership Income
B. Purchase and/or Sale of Personal Property
1. In General
2. Personal Property
3. Purchase and/or Sales Transactions
4. Commission and Fee Income
a. In General
b. Distinguished from Services Income
5. Distinguished from Other Types of Income
C. Purchase and/or Sale Involving Related Persons
1. In General
2. Definition of Related Person
3. Purchases and Sales Involving Only Unrelated Persons
4. Planning Structures
a. Related Person Services
b. Toll Manufacturing
c. Commissionaire Structures
d. Sales to Disregarded Entities
D. Connection with Controlled Foreign Corporation's Country
1. In General
2. Property Manufactured in Controlled Foreign Corporation's Country of Organization
a. In General
b. Manufactured or Produced
c. In the Controlled Foreign Corporation's Country of Organization
(1) In General
(2) Dual Resident
3. Property Sold for Use Within the Controlled Foreign Corporation's Country of Organization
a. In General
b. Country of Use, Consumption, or Disposition
(1) In General
(2) Sales to Unrelated Persons
(3) Sales to Related Persons
(4) Sales to Retailers
(5) Fungible Goods
c. Controlled Foreign Corporation's Country of Organization
E. Property Manufactured or Produced by a Controlled Foreign Corporation
1. In General
2. Definition of Manufacturing
a. Overview—“Physical Manufacturing” and “Substantial Contribution” Manufacturing
b. Physical Manufacturing
(1) In general
(2) Substantial Transformation Test
(3) Substantial Operations Test
c. Substantial Contribution Manufacturing
(1) In General
(2) Indicia of Manufacturing
3. Treatment of Contract and Toll Manufacturing Arrangements under Prior Regulations
a. In General
b. Attribution of Manufacturing Activities
c. Section 954(d)(2) Branch Rule
d. Change in IRS Position
F. Apportionment of Income Derived from Sale of Purchased Components Used in Property Not Manufactured by the Controlled Foreign Corporation
G. Exceptions
1. Property Sold to Unrelated Person After “Substantial Use” by the Controlled Foreign Corporation (Substantial Use Exception)
2. Property Sold as Part of Discontinuing the Controlled Foreign Corporation's Trade or Business
3. Agricultural Commodities
a. General Rule
b. Definition of Agricultural Commodities
c. Agricultural Commodities Included Within Exception
d. Agricultural Commodities Excluded From Exception
(1) General
(2) Specific Commodities Excluded
(3) 50 Percent of Value Attributable to Manufacturing or Processing
H. Foreign Branch of Controlled Foreign Corporation Treated as Separate Corporation
1. General
a. Basic Rules
b. Legislative Background
c. Regulatory Background
2. Definition of Branch
a. In General
b. Contract Manufacturer Not a Branch
(1) Revenue Ruling 75-7
(2) Ashland Oil, Inc. v. Commissioner
(3) Vetco, Inc. v. Commissioner
(4) Revenue Ruling 97-48
3. Purchasing, Selling, or Manufacturing Activities
a. In General
b. Selling and Purchasing Activities
c. Manufacturing Activities
4. Tax Rate Disparity Test
a. In General
b. Comparison of Effective Tax Rates
(1) Purchase or Sales Branch
(2) Manufacturing Branch
c. Determination of the Actual and Hypothetical Effective Tax Rates
(1) Overview
(2) Income Subject to Rate Testing
(a) In General
(b) Relevant Laws
(c) AM 2015-002
(3) Foreign Base Company Sales Income Limitation
d. Actual Tax on Income
e. Hypothetical Tax on Income
(1) Required Assumptions
(2) Pre-2009 Regulations
(3) Effect of Tax Holidays and Negotiated Rate Reductions
f. Multiple Branches
(1) In General
(2) Purchasing or Selling Activities in Multiple Locations
(3) Manufacturing Branch, and One or More Purchase or Sales Branches
(4) Manufacturing in Multiple Locations
(a) In General
(b) If Only One Location Satisfies the Definition of Manufacturing
(c) If More than One Location Satisfies the Definition of Manufacturing
(d) If No Location Satisfies the Definition of Manufacturing
5. Determination of Foreign Base Company Sales Income
a. In General
b. Purchase or Sales Branch Treated as a Separate Corporation
c. Manufacturing Branch Treated as a Separate Corporation
d. Relevant Exceptions
e. Limitations on Separate Corporation Treatment
f. Coordination Rules
(1) Items Not Included Twice
(2) Priority of §954(d)(1)
6. Scope of Branch Rule
a. In General
b. Application of De Minimis and Full-Inclusion Rules
I. Special Rule for Certain Timber Products
J. Coordination with Other Foreign Base Company Income Rules
1. In General
2. Foreign Personal Holding Company Income Rules
a. Priority Rule
b. Single Transaction, Two Categories of Foreign Base Company Income
3. Foreign Base Company Services Income
a. In General
b. Predominant Character
c. Commissions and Fees
d. Tested Once
4. Foreign Base Company Shipping Income
5. Foreign Base Company Oil Related Income Exception
VIII. Foreign Base Company Services Income
A. In General
1. Overview
2. Legislative Background
a. 1962 Tax Act
b. Post-1962 Amendments
(1) Insurance Income
(2) Active Finance, Insurance, and Dealer Income
3. Basic Rules
4. Partnership Income
B. Definition of Services Income
1. In General
2. Types of Services
3. Service Income Distinguished from Other Types of Income
a. Substance of Transaction
b. Purchase and Sales Commissions
c. Coordination Rules
4. Form of Remuneration
C. Services Performed For, or On Behalf Of, a Related Person
1. In General
2. Related Person Requirement
3. For, or On Behalf Of
a. Services Actually Performed for a Related Person
b. Services Deemed Performed for a Related Person
(1) In General
(2) CFC Paid by Related Person for Performing Services
(3) Related Person Obligated to Perform Services
(a) General Rule
(b) Related Person Guaranty of Performance
(4) Services As a Condition or Material Term of a Related Person Property Sale
c. Substantial Assistance Furnished by Related Person
(1) General Rule
(2) Notice 2007-13
(a) In General
(b) Related U.S. Person
(i) In General
(ii) Indirect Assistance
(c) Assistance for Purposes of the 80% Costs Test
(i) In General
(ii) Categories of Assistance Described in the Current Regulations
(iii) Other Assistance
(d) Substantiality of Assistance
(3) Prior Regulations
(4) Current Regulations
(a) Assistance
(i) In General
(ii) Direction, Supervision, Services, and Know-How
(iii) Financial Assistance, Equipment, Material, or Supplies
(b) By a Related Person
(c) Substantial Assistance
(i) In General
(ii) Direction, Supervision, Services, or Know-How
(iii) Financial Assistance, Equipment, Materials, and Supplies
(iv) Aggregation of Assistance
(v) Use of Personnel of Related Person
D. Services Performed Outside the Controlled Foreign Country's Country of Organization
1. General
2. Country of Organization
a. In General
b. CFCs Not Subject to Tax in Their Country of Organization
c. Disregarded Entities
3. Where Services are Performed
4. Apportionment of Services Income
a. In General
b. Activities Incidental to Performing the Contracted Services
c. Activities of Persons Other than the Controlled Foreign Corporation's Employees
d. Location of Machines
E. Exceptions to Foreign Base Company Services Income
1. In General
2. Pre-Sale Services
3. Offers to Sell
4. Securities Dealers
5. Active Finance Income
6. Active Insurance Income
F. Coordination with Other Foreign Base Company Income Rules
1. In General
2. Foreign Personal Holding Company Rules
a. Priority Rule
b. Single Transaction
3. Foreign Base Company Sales Income
a. General
b. Predominant Character
c. Commissions and Fees
d. Tested Once
4. Foreign Base Company Shipping Income
5. Foreign Base Company Oil Related Income
G. Planning Structures
1. Hybrid Entities
2. Services vs. Sales
3. Provision of Services to Related Persons
IX. Foreign Base Company Shipping Income — Pre-2004
A. In General
1. Overview
2. Legislative History
3. Basic Rules
B. Vessel or Aircraft
C. Foreign Commerce
1. General Definition
2. Services to Vessels Used in Foreign Commerce
D. Categories of Foreign Base Company Shipping Income
1. Overview
2. Aircraft or Vessel Used in Foreign Commerce
3. Directly Related Services
a. In General
b. Related Persons
c. Intragroup Services
d. Services for Passengers, Consignors, or Consignees
e. 70-Percent Test and Election
4. Incidental Income
5. Sale of an Aircraft or Vessel
6. Dividends, Interest, and Gains
a. In General
b. Types of Corporations
c. Dividends
d. Interest and Gains
7. Income from Partnerships and Trusts
8. Foreign Exchange Gain or Loss
E. Same-Country Exception
F. Space or Ocean Activity
G. Coordination with Other Foreign Base Company Income Categories
1. Overview
2. Foreign Personal Holding Company Income
3. Foreign Base Company Sales Income
4. Foreign Base Company Services Income
5. Foreign Base Company Oil Related Income
X. Foreign Base Company Oil Related Income
A. General
1. Overview
2. Legislative History
3. Basic Rules
B. Definition of Foreign Base Company Oil Related Income
1. In General
2. Minerals: Oil or Gas
3. Processing Income
4. Transportation Income
5. Distribution or Sales Income
6. Gain from Disposition of Assets
7. Directly Related Services Income
8. Dividends, Interest, Partnership Income
a. In General
b. Foreign Personal Holding Company Income Priority
C. Same-Country Exceptions
1. In General
2. Same Country Use or Consumption Exception
3. Same Country Extraction Exception
4. Source Rules
D. Small Oil Producer Exception
E. Coordination with Other Foreign Base Company Income Categories
1. In General
2. Foreign Personal Holding Company Income
3. Foreign Base Company Sales and Services Income
4. Foreign Base Company Shipping Income
XI. Foreign Base Company Income Special Rules and Exceptions
A. In General
B. De Minimis Rule
1. In General
2. Five Percent/$1 Million Threshold
a. In General
b. Gross Income
c. Currency Translation
3. Separate Application to a Branch
4. Exclusion Inapplicable
a. In General
b. Factoring Income
c. Portfolio Interest
5. Anti-Abuse Rule
a. In General
b. Principal Purpose Test
c. Rebuttable Presumption
(1) Related-Person Controlled Foreign Corporations
(2) Circumstances Creating Presumption
(a) Same Assets or Activities
(b) CFCs as Partners in a Partnership
(c) Activities Constitute Single Branch
(d) Rebutting Presumption
6. Coordination with §952(c)
C. Full-Inclusion Rule
1. In General
2. Character of Full-Inclusion Foreign Base Company Income
3. Exclusion: U.S.-Source Effectively Connected Income
4. Separate Application to a Branch
5. Anti-Abuse Rule
6. Coordination with High-Tax Exception
7. Coordination with §952(c)
D. High-Tax Exception
1. In General
a. Overview
b. Legislative Background
2. Computational Rules
a. General Rule
b. Item-by-Item
c. De Minimis/Full-Inclusion Rules
(1) In General
(2) Exclusion for Full-Inclusion Income
d. Net Foreign Base Company Income
e. Income First Reduced by §952(c) Limitation
3. Definition of Item of Income
a. In General
b. Passive Foreign Personal Holding Company Income
(1) General Definition
(2) Item Classification Rules
(3) Categories of Foreign Personal Holding Company Income
(4) Section 904 Passive Groups
(a) General Rules
(b) Income from Other Sources
(c) Separate Qualified Business Units
(d) Special Classification Rules
c. Income Other Than Passive FPHCI
4. Taxes Paid or Accrued With Respect to an Item of Income
a. General Rules
b. Section 960
(1) In General
(2) Pre-2017 Tax Act Section 960
(a) In General
(b) Separate Categories
(c) Allocation of Taxes
(d) No Direct Tracing Rule
c. Passive Foreign Personal Holding Company Income
d. Taxes Taken into Account
(1) Actually Paid or Accrued
(2) Taxes Paid to Several Countries
(3) Taxes Deemed Paid by CFC
(4) Subsequent Reduction of Taxes
(5) No §904 Limitation
e. Individual Shareholders
5. Effective Foreign Tax Rate
6. 90% of U.S. Corporate Tax Rate
7. Making the Election
a. Procedures
b. Consistency Rules
8. High-Tax Exception Inapplicable
a. Portfolio Interest
b. Foreign Base Company Oil Related Income
c. Section 952(c) Recapture
E. Coordination of Special Rules and Exception with Earnings and Profits Limitations
1. Earnings and Profits Limitations
a. General Rules
b. Recharacterization and Recapture of Earnings and Profits
c. Separate Category Loss Disallowance
(1) General Rule
(2) Earnings and Profits Limitation
(3) Recharacterization and Recapture
2. De Minimis Rule
a. General Rule
b. Earnings and Profits Limitation
c. Recharacterization and Recapture
3. Full-Inclusion Rule
a. General Rule
b. Earnings and Profits Limitation
c. Recharacterization and Recapture
4. High-Tax Exception
a. General Rule
b. Earnings and Profits Limitation
c. Recharacterize and Recapture
XII. Controlled Foreign Corporation Owned Partnerships
A. In General
B. Historical Background of Subpart F Rules Regarding Partnership Distributions
1. Developments Leading to Partnership Regulations
a. Rev. Rul. 89-72
b. The Brown Group Case
c. Notice 96-39
2. Overview of the “Brown Group Regulations”
a. Section 702 Regulations
(1) Character of Partnership Gross Income
(2) Partners Separately Take into Account Subpart F Items
b. Subpart F Regulations
(1) General Aggregate Rule
(2) Foreign Base Company Income Entity Rules
(3) Partnership Investments in U.S. Property
c. Partnership Matters Unaddressed
(1) Controlled Foreign Corporation's Transactions with Partnership
(2) Partnership Deductions
C. Foreign Base Company Income Determinations
1. Related Person
a. General Rules
b. Partner/Partnership Transactions
(1) Controlled Foreign Corporation Partner's Distributive Share
(2) Controlled Foreign Corporation Partner's Own Income
2. Country of Incorporation
D. Foreign Personal Holding Company Income
1. Foreign Personal Holding Company Income General Rules
2. Distributive Share — General Rule
3. Exceptions to Foreign Personal Holding Company Income
a. Active Trade or Business Exceptions in Partnership Context
b. Same-Country Exceptions in Partnership Context
E. Foreign Base Company Sales Income
1. General Rules
2. General Aggregate Approach
3. Manufacturing Exception
a. General Rules
b. Application to Partnership Income
(1) General Rule
(2) Contract Manufacturing
4. Branch Rule
a. General Rule
b. Partnership Regulations
c. Possible Applications of Branch Rule
(1) PLR 201002024
(2) Aggregate Approach
5. Controlled Foreign Corporation Partner/Partnership Transactions
a. In General
b. Distributive Share
(1) Purchase/Sales Transactions
(a) General Rules — §954(d)(1)
(b) Sales Branch Rule — §954(d)(2)
(2) Manufactured Property
(a) Property Manufactured by CFC Partner
(b) Property Manufactured by Partnership
c. Controlled Foreign Corporation Partner's Income
(1) General Rules
(2) Purchase/Sales Transactions
(a) Sale of Products to a Partnership
(b) Purchase of Products from Partnership
(c) Branch Rule
(3) Manufactured Property
(a) Property Manufactured by CFC
(b) Property Manufactured by Partnership
(c) Branch Rule
F. Foreign Base Company Services Income
1. General Rules
2. Distributive Share of Services Income
a. General Aggregate Rule
b. Substantial Assistance
(1) General Rules
(2) Special Entity Rule
G. Foreign Base Company Shipping Income
1. General Rules
2. Distributive Share of Shipping Income
H. Foreign Base Company Oil Related Income
1. General Rules
2. Distributive Share of Foreign Oil Related Income
I. Special Foreign Base Company Income Rules and Exception
1. In General
2. General Aggregate Approach
a. Foreign Base Company Income Special Rules
b. High-Tax Exception
3. De Minimis Anti-Abuse Rule: Entity Approach

Working Papers

Working Papers
Table of Worksheets
Worksheet 1 Pub. L. No. 94-12, H.R. Conf. Rep. No. 120, 94th Cong., 1st Sess. (1975) (Excerpts)
Worksheet 2 General Explanation of the Tax Reform Act of 1976 (H.R. 10612, 94th Cong., Pub. L. No. 94-455) prepared by the Staff of the Joint Committee on Taxation, December 29, 1976 (§§1021, 1024)
Worksheet 3 Tax Equity and Fiscal Responsibility Act of 1982, Report of the Committee on Finance, United States Senate, on H.R. 4961, 97th Cong., 2d Sess., Rept. 97-494, Vol. 1, July 12, 1982 (§217)
Worksheet 4 Tax Equity and Fiscal Responsibility Act of 1982, Conference Report, 97th Cong., 2d Sess., Report No. 97-760, August 17, 1982
Worksheet 5 General Explanation of the Revenue Provisions of the Deficit Reduction Act of 1984 (H.R. 4170, 98th Cong.; Pub. L. No. 98-369) prepared by the Staff of the Joint Committee on Taxation, December 31, 1984 (§§121, 123)
Worksheet 6 H.R. Rep. No. 111, 103d Cong., 1st Sess. (1993) (§§14231–14233)
Worksheet 7 H.R. (Conf.) Rep. No. 213, 103d Cong., 1st Sess. (1993)
Worksheet 8 Prop. Reg. §§1.954-1 through -5, 27 Fed. Reg. 12,759 (12/27/62)
Worksheet 9 Reg. §§1.954-1 through -5, T.D. 6734, 1964-1 C.B. (Part 1) 237
Worksheet 10 Prop. Reg. §1.954-4, 32 Fed. Reg. 3,155 (2/27/67)
Worksheet 11 Reg. §1.954-4, T.D. 6981, 1968-2 C.B. 314
Worksheet 12 Technical Memorandum attached to T.D. 6981, 1968 TM Lexis 11 (11/5/68)
Worksheet 13 Technical Memorandum accompanying T.D. 7503, 1976 TM Lexis 77 (4/12/76)
Worksheet 14 Preamble to T.D. 7894, 1983-1 C.B. 149
Worksheet 15 REG-104537-97, 1998-16 I.R.B. 21 (4/20/98)
Worksheet 16 REG-112502-00, 65 Fed. Reg. 56,836 (9/20/00)
Worksheet 17 T.D. 9008, 67 Fed. Reg. 48,020 (7/23/02)
Worksheet 18 Election for High-Tax Exception