Foreign Sales Corporation

• Foreign sales corporations

• 26 CFR 1.921-3T - Temporary regulations; Foreign sales corporation general rules.

• Code of Federal Regulations - Title 26: Internal Revenue

• 26 CFR 1.927(f)-1 - Election and termination of status as a Foreign Sales Corporation.

• Code of Federal Regulations - Title 26: Internal Revenue

• Union Carbide Foreign Sales Corporation, et al., (2000)

115 T.C. No. 32 UNITED STATES TAX COURT UNION CARBIDE FOREIGN SALES CORPORATION, ET AL.,1 Petitioners ...

• United States Tax Court

• T.D. 9438

D. 9438, under Section 954, relates to foreign base company sales income in cases in which personal property sold by a controlled foreign corporation is manufactured, produced, or constructed pursuant to a contract manufacturing arrangement or by one or more branches of the controlled foreign corporation. A public hearing on the proposed regulations is scheduled for April 20, 2009.

• United States. Internal Revenue Bulletin
• September 02, 2009

• Income Taxes: Foreign Management and Foreign Economic Processes Requirements of a Foreign Sales Corporation; CFR Correction

• FR, March 31, 2009
• Rules
• Internal Revenue Service

• 'Active' FSCs (and IC-DISCs) may qualify for double tax benefits.

Foreign sales corporation, interest-charge domestic international sales corporation Permanent tax exemptions are available to US companies that export products through the use of foreign sales corporations (FSCs) and interest-charge domestic international sales corporations (IC-DISCs). Commission-based FSCs are eligible for a 15% permanent exemption in addition to limited taxation of the commissions received by the FSC. Active FSCs may be eligible for 30% permanent exemptions. Profits for IC-DISCs may be exempt up to 100% if the sales corporations are considered active.

• The Tax Adviser
• Vol. 26 Nbr. 9, September 1995

• Guidance Regarding Foreign Base Company Sales Income

This document contains final regulations that provide guidance relating to foreign base company sales income when personal property sold by a controlled foreign corporation (CFC) is purchased, sold, manufactured, produced, constructed, grown or extracted by one or more branches of the CFC. The regulations finalize proposed regulations and withdraw temporary regulations published on December 29, 2008. These regulations, in general, affect controlled foreign corporations and their United States shareholders.

• Federal Register Nbr. 76 FR 78545, December 19, 2011
• Rules and Regulations
• Treasury Department

• 26 CFR 1.927(d)-2T - Temporary regulations; definitions and special rules relating to Foreign Sales Corporation.

• Code of Federal Regulations - Title 26: Internal Revenue

• Income taxes: Foreign sales corporation transfer pricing; source rules,

• FR, September 21, 1998
• Rules
• Internal Revenue Service

• The shared foreign sales corporation: a tax saving opportunity for small business.

The US government offers income tax exemption to foreign sales corporations (FSCs). However, FSCs must satisfy several requirements regarding their organization, management and economic processes to qualify for the 15% exemption as specified in the 1984 Tax Reform Act. For many smaller exporters the rules on shared FSCs may apply to them. Small business owners can ask the assistance of several state agencies of economic development and trade associations if they need help in complying with income tax exemption requirements.

• The National Public Accountant
• Vol. 39 Nbr. 12, December 1994