Applying the Subpart F Services Rules to Disregarded Entity Structures
Commerce Clearing House (CCH) International Tax Journal
Lowell Yoder wrote this bylined article on the Subpart F tax requirement that US shareholders include in gross income a foreign subsidiary’s services income to the extent it meets the definition of foreign base company services income. “Services income that does not satisfy both the locational and the related-person requirements is not foreign base company services income,” Mr. Yoder wrote. “Therefore, services performed for persons who are unrelated to the CFC [controlled foreign corporation] generally do not give rise to foreign base company services income. Read the full article.