- 58 - 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.......... 300Page: Previous 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 Next
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