Bausch & Lomb Incorporated and Consolidated Subsidiaries - Page 60

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               from this definition.                                                  
                    The sales income with which your committee is                     
               primarily concerned is income of a selling subsidiary                  
               (whether acting as principal or agent) which has been                  
               separated from manufacturing activities of a related                   
               corporation merely to obtain a lower rate of tax for                   
               the sales income. * * *  [S. Rept. 1881, 87th Cong., 2d                
               Sess. (1962), 1962-3 C.B. 703, 790.]                                   
          In their technical explanations of the bill enacting subpart F,             
          both the Senate Finance Committee and the House Ways and Means              
          Committee further explained that the definition of "foreign base            
          company sales income":                                                      
               does not apply to income of a controlled foreign cor-                  
               poration from the sale of a product which it manufac-                  
               tures.  In a case in which a controlled foreign cor-                   
               poration purchases parts or materials which it then                    
               transforms or incorporates into a final product, income                
               from the sale of the final product would not be foreign                
               base company sales income if the corporation substan-                  
               tially transforms the parts or materials, so that, in                  
               effect, the final product is not the property pur-                     
               chased.  Manufacturing and construction activities (and                
               production, processing, or assembling activities which                 
               are substantial in nature) would generally involve                     
               substantial transformation of purchased parts or ma-                   
               terials.  [S. Rept. 1881, supra, 1962-3 C.B. at 949;                   
               H. Rept. 1447, 87th Cong., 2d Sess. (1962), 1962-3 C.B.                
               at 592-593.]                                                           
               Under 954(d)(1), if a CFC purchases property from a related            
          person that it sells to any person for use or consumption outside           
          the country under which it is organized, a U.S. shareholder of              
          that CFC is subject to U.S. income tax on that stockholder's pro            
          rata share of the income generated by such sale unless the prop-            
          erty sold is manufactured, produced, grown, or extracted in the             






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