Non-Subpart F Sales Income: Employee Substance Generally Is Not a Requirement
International Tax Journal, A Note from the Editor-in-Chief
Lowell Yoder wrote this bylined article, which discusses the scope of the definition of Subpart F sales income. It points out that while employee-substance is required to satisfy the manufacturing exception, this is not a requirement to fall outside the general definition of Subpart F sales income. The plain language of the Code and Regulations as well as case law supports this conclusion, Mr. Yoder wrote.