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which includes, inter alia, foreign base company sales income.
Section 954(d)(1) provides, in pertinent part, as follows:
SEC. 954. FOREIGN BASE COMPANY INCOME.
(d) Foreign Base Company Sales Income.--
(1) In general.--For purposes of subsection
(a)(2), the term “foreign base company sales income”
means income (whether in the form of profits,
commissions, fees, or otherwise) derived in connection
with the purchase of personal property from a related
person and its sale to any person, the sale of personal
property to any person on behalf of a related person,
the purchase of personal property from any person and
its sale to a related person, or the purchase of
personal property from any person on behalf of a
related person where--
(A) the property which is purchased (or in
the case of property sold on behalf of a related
person, the property which is sold) is
manufactured, produced, grown, or extracted
outside the country under the laws of which the
controlled foreign corporation is created or
organized, and
* * * * * * *
For purposes of this subsection, personal property does
not include agricultural commodities which are not
grown in the United States in commercially marketable
quantities.
The language of section 954(d)(1)(A) appeared in almost
identical form as proposed new Code section 952(e)(2)(A) in H.R.
10650 (bill pp. 112-113), the Revenue Act of 1962, as reported by
the House Ways and Means Committee. The enacted language
appeared in identical form as proposed new Code section
954(d)(1)(A) in H.R. 10650 (bill p. 190), as reported by the
Senate Finance Committee. H. Conf. Rept. 87-2508 (1962), 6-7
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