Dover Corp. v. Commissioner, 122 T.C. No. 19 (May 5, 2004) (CFC's sale of subsidiary stock treated as sale of assets received in section 332 liquidation of subsidiary pursuant to retroactive disregarded entity classification election; gain on sale of subsidiary stock treated as gain on sale of assets used in CFC's business and, thus, not subpart F income)
The Limited, Inc. v. Commissioner, ___ F.3d ___, 2002 U.S. App. LEXIS 6676 (6th Cir. 2002), rev'g 113 T.C. 169 (1999) (CDs purchased by fourth-tier CFC with negligible E&P from taxpayer's wholly-owned credit card company/national bank were deposits with a person "carrying on the banking business" within meaning of section 956 exception to definition of "United States property")
Electronic Arts, Inc. v. Commissioner, 118 T.C. No. 13 (2002) (discussion of "manufacturing" within meaning of section 954(d)(1)(A), as incorporated in section 936(h)(5)(b)(ii) flush language)
Stanford v. Commissioner, 82 A.F.T.R. 2d ¶ 98-5263 (5th Cir. 1998) (Section 952)
Bausch & Lomb, Inc. v. Commissioner, T.C. Memo. 1996-57 (sunglasses "manufactured" within meaning of Section 954(d)(1))
Brown Group v. Commissioner, 77 F.3d 217 (8th Cir. 1996), rev'g 104 T.C. 105 (1995) (section 954(d))
Ashland Oil, Inc. v. Commissioner, 95 T.C. 348 (1990) (corporation functioning as contract manufacturer under arm's-length contract with unrelated CFC is not "branch or similar establishment" of CFC under Section 954(d)(2); Cf. Rev. Rul. 75-7 and Rev. Rul. 97-48)
Vetco, Inc. v. Commissioner, 95 T.C. 579 (1990) (second-tier wholly-owned subsidiary is not "branch" for purposes of Section 954(d)(2))
FSA 200220005 (Activities of consignment contract manufacturer not attributable to CFC for purposes of satisfying manufacturing exception; sales income is foreign base company sales income as defined in section 954(d)(1))
Brown Group Regulations (T.D. 9008, July 23, 2002)
Proposed Brown Group Regulations
Office of Tax Policy, Department of the Treasury, The Deferral of Income Earned Through U.S. Controlled Foreign Corporations - A Policy Study, December 2000
Proposed Hybrid Branch Regulations
Notice 98-35, 1998-27 I.R.B. 1 (Issued June 19, 1998)
Proposed (Brown Group) Partnership Regulations
Temporary Hybrid Branch Regulations
Notice 98-11, 1998-6 I.R.B. 18 (Issued January 16, 1998)
Rev. Rul. 97-48, 1997-49 I.R.B. 5
Notices 98-11 and 98-35:
The Hybrid Branch Controversy
IRS Changes Position on CFC-Contract Manufacturing
TAM 200437033 (voluntary restrictions on CFC's ability to currently distribute E&P to domestic shareholder do not relieve taxpayer from duty to include pro-rata share of CFC's subpart F income in its own taxable income)
PLR 200419014 (corporation will succeed to share of two foreign corporations' respective qualified deficits)
PLR 200411016 (IRS revokes PLR 200229030)
PLR 200229030 (CFC interest in software not U.S. property for purposes of section 956)
PLR 9852033 (retention of U.S. trademarks does not affect transfer of foreign trademarks to intangible holding company)
TAM 8509004 (manufacturing branch rule does not apply where remainder CFC performs no selling function)
Regs. 1.957-1(c), Examples 8 and 9
Shifting Voting Power in Attempt to Avoid CFC Status
Form 1120, Schedule N Foreign Operations of U.S. Corporations (2005)
Form 5471 Information Return of U.S. Persons With Respect to Certain Foreign Corporations (Rev. December 2005)
Form 5471 Schedule J (Rev. December 2005)
Form 5471 Schedule M (Rev. December 2005)
Form 5471 Schedule N ((Rev. December 2004)
Form 5471 Schedule O (Rev. December 2005)
Form 5471 Instructions (Rev. December 2005)
Form 8895 One-Time Dividends Received Deduction for Certain Cash Dividends from Controlled Foreign Corporations (August 2005)
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