General Dynamics Corporation and Subsidiaries - Page 15

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          subsidiaries.  H. Rept. 92-533, at 58 (1971), 1972-1 C.B. 498,              
          529; S. Rept. 92-437, at 90 (1971), 1972-1 C.B. 559, 609.  A                
          domestic corporation that conducts its foreign operations through           
          a foreign subsidiary generally does not pay domestic Federal tax            
          on the income from those operations until the subsidiary's income           
          is repatriated to the domestic parent.                                      
               In 1984, Congress enacted the FSC provisions5 to replace and           
          cure some shortcomings in the DISC provisions.  Deficit Reduction           
          Act of 1984, Pub. L. 98-369, sec. 801(a), 98 Stat. 494, 990; S.             
          Rept. 98-169, at 636 (1984).  Under the FSC provisions, a                   
          taxpayer may permanently avoid Federal income tax on a portion of           
          its profits on qualifying export sales.                                     
               The DISC and FSC provisions reallocate income generated by             
          export sales from the parent corporation to its DISC or FSC.                
          DISC’s are generally not subject to tax.  Sec. 991.  However, the           
          parent corporation is taxed on a specified portion of the DISC              
          profits as a deemed distribution.  Sec. 995; L & F Intl. Sales              
          Corp. v. United States, 912 F.2d 377, 378 (9th Cir. 1990).  The             
          remaining profits are tax-deferred until distributed                        
          (repatriated) to the parent or until the corporation ceases to              
          qualify as a DISC.  Secs. 995(a) and (b) and 996(a)(1).  The FSC            
          provisions permanently exempt a portion of FSC profits from tax.            
          Sec. 923(a).  The amount of the deferral or exemption is in                 


               5 Secs. 921-927.                                                       




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