The Coca-Cola Company, and Includible Subsidiaries - Page 16

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               A possession product is an item of property which is the               
          result of a production process carried on in a possession. Sec.             
          1.936-5(a), A-1, Income Tax Regs.  Possession products encompass            
          component products, integrated products, and end-product forms.             
          Id.  A component product is a product which is subject to further           
          processing before sale to an unrelated party.  Id.  An integrated           
          product is (1) a product not subject to any further processing              
          before sale to an unrelated party and (2) a product which                   
          includes all component products from which it is produced.  Id.             
          A possessions corporation may treat a component product or an               
          integrated product as its possession product even though the                
          final stage or stages of production occur outside the possession.           
          Id.  Further processing includes transformation, incorporation,             
          assembly, or packaging.  Id.  For our purposes, the integrated              
          product is syrup or soft drinks, the component product is                   
          concentrate, and the possession product is the component                    
          concentrate.  Again, CRI is both the possessions corporation and            
          the electing corporation within the meaning of section 936.                 
               CRI incurs costs in producing and shipping concentrate to              
          the United States.  Production costs include direct labor costs             
          and overhead incident to and necessary for production but do not            
          include direct material costs and interest.  Secs. 1.936-6(b)(1),           
          Q&A 12, 1.936-5(b)(4), 1.471-11(b), Income Tax Regs.  USA and the           
          CBO's incur expenses in selling the syrup and soft drinks.  U.S.            
          affiliate expenses allocable and apportionable to the integrated            




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