Electronic Arts, Inc. and Subsidiaries - Page 75




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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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