...the gross insurance income of a controlled foreign corporation is less than the lesser of — (7)5 percent of gross income, or (2) $1,000,000. Controlled...income because the full inclusion test of paragraph (b XIX iii) of this section is met are termed "full inclusion foreign base company income," and constitute...

...income. (iii) Seventy percent full inclusion test. The full inclusion rule of this paragraph (b)(l)(iii) applies if the sum of the foreign base company income...of adjusted gross foreign base company income for purposes of allocating and apportioning deductions under paragraph (c) of this section. (3) Coordination...

...income and the gross insurance income for the taxable year exceeds 70 percent of gross income. §4.954-1 (2) Character of items of gross income included in...income because the full inclusion test of paragraph (b)(l)(iii) of this section is met are termed "full inclusion foreign base company income," and constitute...

...foreign corporation retain their character as foreign personal holding Interned Revenue Service. Treasury company Income, foreign base company sales income,...income because the full inclusion test of paragraph (b)(l)(iii) of this section is met are termed "full inclusion foreign base company income," and constitute...

...corporation retain their character as foreign personal holding company income, foreign base comралу sales income, foreign base company services income,...income because the full inclusion test of paragraph (b)(l)(iii) of this section is met are termed "full inclusion foreign base company income," and constitute...

...adjusted gross foreign base company income of a controlled foreign corporation generally retains its character as foreign personal holding company income,...income, or foreign base company oil related income. However, gross income included in adjusted gross foreign base company income because the full Inclusion...

...income (as determined under §1.954-6) of a controlled foreign corporation shall not also be considered foreign personal holding company income, foreign base...sales income, foreign base company services income, or foreign base company oil related income. See section 954(b)(6)(A) and (b)(8). However, foreign base...

...income (as determined under § 1.954-6) of a controlled foreign corporation shall not also be considered foreign personal holding company income, foreign base...sales income, foreign base company services income, or foreign base company oil related income. See section 954ФХ6ХА) and (b)(8). However, foreign...

...regulations so that there may be taken into account deductions (including taxes) properly allocable to foreign personal holding company income, foreign base...sales income, foreign base company services income, and gross income to which section 954(b)(3)(B) applies. What types of deductions? Deductions ascertained...

...on the undistributed profits of controlled foreign corporations to the extent they are derived from foreign personal holding company income, foreign base...sales income, foreign base company services income, and any earnings am! profits invested in US property. Except for the foregoing, earnings of foreign...