The Agricultural Commodities Exception to Foreign Base Company Sales Income
Bloomberg BNA International Tax Library
Lowell Yoder wrote this bylined article about a recent Chief Counsel Advice (CCA) regarding an exception for processed or manufactured agricultural products from the definition of foreign base company sales income. Mr. Yoder wrote that the CCA addressed whether a 2009 amendment to the foreign base company sales income regulations eliminated that limitation, and concluded that the limitation still applies. Read the full article.