The Section 163(j) limitation will apply to any CFC
that has at least one U.S.
1.951A-6: Treatment of GILTI inclusion amount and adjustments to E&P and basis related to tested loss CFCs
earned 23.3 percent of the E&P (less deficit) before income taxes for all corporate-owned CFCs
When the branch is deemed as a manufacturing branch, the branch is treated as a subsidiary of the CFC
in which the CFC
is performing selling activities on behalf of the manufacturing branch.
The conversion was beneficial for Quimobasicos because demand for CFCs
was waning as appliance manufacturers switched to more environmentally friendly products.
The police said the two sold at least 100,000 cans of CFCs
to automobile maintenance shops through intermediary agents since March and made a profit of some 300 million yen.
"We did the easy thing: We got rid of the CFCs
. But when you try to get people to talk about methyl bromide and ozone depletion, about global warming and ozone depletion, it's like pulling teeth."
Keeping with the Montreal Protocol, the aim is to halt CFC
production in India within the next 10 years, the release said.
Black market profiteers exploit a gray area in the Montreal Protocol, the international treaty that has restricted the trade of CFCs
since 1990 and has banned production in industrial countries since 1996 - except for a small volume produced for export to developing countries or for "essential uses" such as asthma inhalers in industrial countries.
There has been rapid progress made in reducing the use of CFCs
in the industrialized countries.
The illicit CFCs
are used in repairs of existing appliances and automobiles.
When DuPont and each of the major manufacturers of CFCs
officially stopped producing these ozone-depleting refrigerants on December 31, 1995, a "greener" world became a reality for building owners and managers nationwide.
As she told her radio audience: "The whole idea of CFCs
destroying ozone is not based on any scientific evidence.
Damage to the ozone layer in the stratosphere may begin to abate as early as the turn of the century, thanks to concerted efforts by the refrigeration and other industries as well as world governments to halt the use of chlorofluorocarbons (CFCs
of Brazil reports on neutron activation analysis as a quick, non-destructive method for determining content of CFCs
, HCFCs or HFCs in rigid foams either in the gaseous phase or dissolved in the foam cell walls.