Cross-border equipment leasing: recent developments related to section 168(g)
Article Abstract:
Congress should amend IRC section 168(h) to establish that foreign sales corporation (FSC) leases are not subject to the depreciation limitations of section 168(g). When section 168(g) was enacted, US investors began using FSCs in replacement lease arrangements with shortened depreciation periods to compensate for depreciation limitations. 1996 final regulations under IRC section 168(g) disallowed replacement leases in the FSC context. To promote international economic competitiveness, Congress should exempt FSC leases from 168(g) depreciation limitations.
Publication Name: Virginia Tax Review
Subject: Law
ISSN: 0735-9004
Year: 1996
User Contributions:
Comment about this article or add new information about this topic:
Structuring and taxing the FSC leasing transaction
Article Abstract:
Foreign sales corporations (FSCs) must meet transactional and structural requirements to receive tax benefits such as exemption from taxation as foreign source income. FSC transactions can take the form of leases, and the structure of the lease depends on whether the FSC is an ownership FSC or is a commission FSC. FSC status also has implications for depreciation and dividend distributions. Transfer price regulations are also relevant to the proper reporting of the values of FSC transactions.
Publication Name: Journal of Taxation of Investments
Subject: Law
ISSN: 0747-9115
Year: 1995
User Contributions:
Comment about this article or add new information about this topic:
Forming a foreign sales corporation can shield rental income from tax
Article Abstract:
US exporters involved in international leasing have used the structure of the foreign sales corporation (FSC) for tax benefits. After certain requirements are met, a percentage of the FSC's income is exempt from US income tax. The FSC must meet structural requirements including those concerning place of incorporation, shareholder constituency and outstanding stock. The FSC must meet other requirements concerning foreign participation and management as well as export income.
Publication Name: Journal of Taxation of Investments
Subject: Law
ISSN: 0747-9115
Year: 1993
User Contributions:
Comment about this article or add new information about this topic:
- Abstracts: Insider trading: a new cycle. Amendments to section 16 "short-swing" insider trading rules
- Abstracts: When good intentions lead to bad results. Guidelines have led to longer sentences
- Abstracts: Israeli Supreme Court begins to Americanize law; it has recently cited the U.S. high court in speech, religion, sexual discrimination cases
- Abstracts: Teacher bargaining in Minnesota: retrospect on the 1980s and prospects of fewer bargaining units. Collective bargaining and educational reform: establishing a labor-management partnership
- Abstracts: 'Case closed' excerpts: author attempts to dismantle conspiracies. Book: despite its errors, the Warren Commission reached the right result