The Coca-Cola Company, and Includible Subsidiaries - Page 10

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                                   income of the affiliated group (other              
                                   than foreign affiliates) derived from              
                                   covered sales of units of the product              
                                   produced * * *, in whole or in part, by            
                                   the electing corporation in a                      
                                   possession.                                        
                                        (II) Computation of combined                  
                                   taxable income.--Combined taxable income           
                                   shall be computed separately for each              
                                   product produced * * *, in whole or in             
                                   part, by the electing corporation in a             
                                   possession.  Combined taxable income               
                                   shall be computed (notwithstanding any             
                                   provision to the contrary) for each such           
                                   product * * * by deducting from the                
                                   gross income of the affiliated group               
                                   (other than foreign affiliates) derived            
                                   from covered sales of such product * * *           
                                   all expenses, losses, and other                    
                                   deductions properly apportioned or                 
                                   allocated to gross income from such                
                                   sales * * * and a ratable part of all              
                                   expenses, losses, or other deductions              
                                   which cannot definitely be allocated to            
                                   some item or class of gross income,                
                                   which are incurred by the affiliated               
                                   group (other than foreign affiliates).             
                                   * * *                                              
                              *    *    *    *    *    *    *                         
                         (7)  Regulations.--The Secretary shall prescribe             
                    such regulations as may be necessary or appropriate to            
                    carry out the purposes of this subsection * * *                   
                    [Emphasis added.]                                                 
               In the simplest terms, section 936(a) allows for a tax                 
          credit.  The amount of this credit is equal to the portion of tax           
          attributable to the "taxable income" derived from conducting                
          business in a possession.  Section 936(h) determines the                    
          treatment of intangible property income.  Intangible property is            
          broadly defined in section 936(h) and includes, of relevance                





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