Complications arise when a CFC
employs a branch or branches to perform sales or manufacturing activities for the CFC
outside the country where the CFC
was created or organized.
In fact, CFCs
are illegal under both international and domestic rules, unless they've been obtained from used equipment.
Sonny Bautista, CFC
Communications Director in Toronto advises, "We defend the Magisterium and are behind the Pope.
The purpose of both forms, one for CFC
reporting and the other for foreign partnership reporting, seems to be identical.
Since the launch of a nationwide CFC
enforcement initiative in 1995, which involves the United States Customs Service, the EPA, the FBI and the IRS, over 100 individuals have been convicted for violation of customs law and the federal Clean Air Act.
A lively and lucrative black market has sprung up, with canisters of gaseous CFCs
sold to dealers and service stations that use the chemical mostly to refill air conditioners in automobiles made before 1994.
The major manufacturers had voluntarily agreed to phase-out the most widely used CFCs
, those known as R-11 and R-12, long before the legal phaseout date.
Because subpart F income is defined as income earned by a CFC
, the court ruled that commission income earned by Brinco could not be considered foreign base company sales income.
Bomberg adds, "Findings of our much more complex approach to this issue leads us to believe that the half-life [or time for loss of half the blowing agent from the foam to the atmosphere] of CFCs
and, more significantly, HCFCs in PUR foams is far longer than is currently believed.
Additional information about CFC
is available on CFC
's Web site at www.
While the CFC
lookthrough rule applies to payments received by a CFC
from a related CFC
, how does the rule apply to payments made by a partnership to its more-than-50% partner that is a CFC
Four of India's largest chlorofluorocarbon (CFC
) manufacturers voluntarily agreed on 2 May 2002 to use cleaner production technologies to help reduce "rogue" CFC
emissions--those emitted during manufacturing--as well as emissions of other chemicals that can harm the ozone layer or local air quality.
They identified more than 300 organic substances, but only one of them was a CFC
The Notice sets forth two examples of "abusive" transactions, which essentially involve a loan (and the attendant payment of interest) with a CFC
in one country and a hybrid branch in another country.
are not supposed to be manufactured after December 31st, but DuPont and Allied Signal, the main suppliers, have already stopped manufacturing both CFC
's R-11 and R-12, the refrigerants most widely used since the middle of the century for large buildings, food storage and automobiles.