Whirlpool: Allocating Income to a Mfg. Branch Under the Regs

Another Spin on Whirlpool: Allocating Income to a Manufacturing Branch Under the Regs

Overview


Lowell Yoder, David Noren, Jonathan Lockhart and Elizabeth Lu author this article in Tax Notes that provides an analysis of the determination under the regulations of the amount of a CFC’s sales income allocated to its manufacturing branch. The amount allocated to the branch qualifies for the manufacturing exception, and is not foreign base company sales income.

Click here to view the 1996 FSA referenced within the article.