shareholders of a CFC
are currently taxed on their pro rata share of the CFC
's subpart F income (Sec.
As of the mid-1990s, some 20,000 tons of CFCs
were being traded through black market channels, according to the EIA.
Schedule M (Transactions Between CFC
and Shareholders or Other Related Persons)
In the 1970s, scientists first discovered that CFCs
and other chemicals could damage the Earth's protective ozone layer, which shields life on Earth from the harmful effects of ultraviolet (UV) radiation.
appeared in the samples from the years before the chemicals were used industrially.
An indictment in San Diego is that district's 10th case involving the apparent smuggling of CFCs
across the Mexican border, and a case filed in Houston was one of several similar prosecutions.
At this stage of the phase-out, many experts expected that CFCs
would no longer be in use.
Published by EPA with little fanfare, the rules officially list "acceptable" replacements for potential use in an estimated 130 million cars and 90 percent of the nation's largest buildings which still use ozone-depleting CFC
For this purpose, all members of a "CFC
group" (one or more chains of CFCs
linked by common ownership with a top-tier CFC
) are treated as though they are one corporation.
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.
954(c)(6)--dividends, interest, rents, or royalties received from a CFC
that is a related person with respect to the recipint CFC
are not treated as FPHCI to the extent attributable or properly allocable to income of the payer CFC
that is neither subpart F income nor income effectively connected with a trade or business in the United States.
Although China and India have supplied some black market CFCs
, Brack finds that Russia and its former republics are "a significant source of most of the illegally traded materials.
are used in more than 3,500 applications, including accelerants for spray paint and hair spray.
The issuance of Notice 88-108 was the third step in IRS and Treasury's guidance on the treatment of loans made by CFCs
to their U.
In addition, all Ford component and vehicle assembly plants in North America have eliminated use of CFCs
in their manufacturing processes.