Source Rules for Foreign Sales Corporation Transfer Pricing
other · IRS · Rule · Published 1998-09-21 · 63 FR 50143
Document
Document number
98-25045
Federal Register citation
63 FR 50143
CFR reference
26 CFR 1
Type
Rule
Action
Final regulations.
Category
other
Sub-agency
IRS
Publication date
1998-09-21
Treasury docket
TD 8782
Abstract
This document contains final regulations that provide guidance to taxpayers who have made an election to be treated as a foreign sales corporation (FSC). The regulations clarify that the special source rule under section 927(e)(1) applies only to income of related suppliers from sales of export property giving rise to foreign trading gross receipts of a FSC.