- 6 -
income listed in subparagraphs (A) through (I) of section
904(d)(1).3 We concern ourselves with two of these baskets. The
first, subparagraph (I), is referred to as general limitation
income. The other is subparagraph (A), referred to as passive
income. In pertinent part, section 904(d)(2)(A) defines passive
income as “any income received or accrued by any person which is
of a kind which would be foreign personal holding company income
3 Sec. 904(d)(1) provides:
In general. The provisions of subsections (a), (b), and
(c) and sections 902, 907, and 960 shall be applied
separately with respect to each of the following items
of income:
(A) passive income,
(B) high withholding tax interest,
(C) financial services income,
(D) shipping income,
(E) in the case of a corporation, dividends
from each noncontrolled section 902
corporation,
(F) dividends from a DISC or former DISC (as
defined in section 992(a)) to the extent
such dividends are treated as income
from sources without the United States,
(G) taxable income attributed to foreign
trade income (within the meaning of
section 923(b)),
(H) [certain] distributions from a FSC...,
and
(I) income other than income described in
any of the preceding subparagraphs.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011