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What is the manufacturing exception for contracts?

Reg. 1.954-3(a)(4)(i) (the manufacturing exception) provides that a FBCSI does not include income of a CFC derived in connection with the sale of personal property manufactured, produced or constructed by the corporation.

What triggers subpart F income?

When a CFC buys/sells tangible personal property (1) from/to (or on behalf of) a related person and the property is (2) manufactured, produced, constructed, grown, or extracted outside the CFCs country of incorporation and the property is purchased/sold (3) for use, consumption or disposition outside the CFCs country

What is the manufacturing branch rule?

Under the manufacturing branch rule, when 1) a CFC conducts manufacturing outside its country of incorporation by or through a branch or similar establishment, and 2) the use of the branch has substantially the same tax effect as if the branch were a wholly owned subsidiary deriving the income,1 the manufacturing

What are the sales branch rules?

The branch rules prevent a US shareholder from using a branch, in lieu of a separate CFC, to shift sales income from a high-tax foreign country to a low-tax foreign country. Absent the branch rules, a CFC and its branch would be treated as a single entity for US tax purposes.

What is the manufacturing exception for contracts?

Reg. 1.954-3(a)(4)(i) (the manufacturing exception) provides that a FBCSI does not include income of a CFC derived in connection with the sale of personal property manufactured, produced or constructed by the corporation.

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