Source and Grouping Rules for Foreign Sales Corporation Transfer Pricing

This document contains temporary regulations that provide guidance to taxpayers who have made an election to be treated as a foreign sales corporation (FSC). The regulations provide rules that clarify the special sourcing rules under section 927(e)(1) and provide a deadline for the election to group transactions. The text of the temporary regulations also serves as the text of the proposed regulations on this subject in the Proposed Rules section of this issue of the Federal Register.