Bausch & Lomb Incorporated and Consolidated Subsidiaries - Page 63

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                       Conversion costs (direct labor and                             
                       factory burden).......................                         
                       70                                                             
                       Total cost of goods sold...............                        
                       210                                                            
                  Gross profit...................................  190                
                  Administrative and selling expenses............   50                
                  Taxable income.................................  140                
               The conversion costs incurred by A Corporation are more                
               than 20 percent of total costs of goods sold ($70/$210                 
               or 33 percent).  Although the product sold, an engine,                 
               is not sufficiently distinguishable from the components                
               to constitute a substantial transformation of the                      
               purchased parts within the meaning of subdivision (ii)                 
               of this subparagraph, A Corporation will be considered                 
               under this subdivision to have manufactured the product                
               it sells.                                                              
                    Example (2).  Controlled foreign corporation B,                   
               incorporated under the laws of foreign country X,                      
               operates an automobile assembly plant.  In connection                  
               with such activity, B Corporation purchases from re-                   
               lated persons assembled engines, transmissions, and                    
               certain other components, all of which are manufactured                
               outside of country X; purchases additional components                  
               from unrelated persons; conducts stamping, machining,                  
               and subassembly operations; and has a substantial                      
               investment in tools, jigs, welding equipment, and other                
               machinery and equipment used in the assembly of an                     
               automobile.  On a per unit basis, B Corporation's                      
               selling price and costs of such automobiles are as                     
               follows:                                                               
                  Selling price................................ $2,500                
                  Cost of goods sold:                                                 
                  Material--                                                          
                       Acquired from related                                          
                  persons................ $1,200                                      
                       Acquired from others.....    275                               
                       Total material............... $1,475                           
                       Conversion costs (direct labor and                             
                       factory burden)..................    325                       
                       Total cost of goods sold.............                          
                       1,800                                                          
                  Gross profit.................................    700                
                  Administrative and selling expenses..........    300                






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