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Related to subpart: Subpart F
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The treatment of Subpart F income in the water's-edge group is significantly different from its treatment for federal tax purposes.
Nasdaq: KERX; AIM: KRX) announced that it has designed a Subpart H (accelerated approval) development plan in collaboration with the FDA for KRX-101, Keryx's Fast-Track investigational drug for the treatment of diabetic nephropathy.
shareholder that has ownership of stock in a CFC on the last day of the CFC's tax year (or the last day in a year the corporation was a CFC) must include its pro rata share of the CFC's subpart F income for that tax year in its gross income regardless of whether the CFC actually makes a distribution to the U.
An exception to subpart F income inclusion occurs (and, thus, a U.
Reorganizes and revises the subpart text for ease of use.
Subpart F income and FPHC income are deemed to be distributed on the last day of the taxable year of the CFC or FPHC.
Active financing and insurance income exception: Subpart F imposes immediate taxation on the income earned by foreign subsidiaries of U.
Subpart G--Financial Subsidiaries of State Member Banks
3 interface with master/slave, flexible expansion port with dedicated RISC IO processor and is designed to be compliant with FCC Part 15 Subpart F.
The Tax Reform Act of 1986 (TRA '86) added to the Code subpart J (foreign currency transactions) and Sec.
The Foreign Procurement Policy Committee is proposing a revision to DFARS Subpart 225.
In effect, the definition implicitly creates a seventh broad category of reportable transactions for transactions undertaken by a controlled foreign corporation that reduce the shareholder's Subpart F income.
10) Subpart J governs the conduct of merchant banking investment activities by financial holding companies as permitted under section 4(k)(4)(H) of the Bank Holding Company Act (12 U.
Their experience includes advice in corporate tax planning; acquisitions; dispositions; joint ventures and reorganizations; tax-advantaged international financings and derivative transactions; foreign tax credit optimization; Subpart F issues; and REITs.
Although a detailed discussion of the anti-deferral rules is beyond this item's scope, a basic understanding of subpart F as it applies to foreign captives is necessary (ignoring, for this item's purposes, the foreign personal holding company provisions).