PROPOSED REGS CONTRAVENE CONGRESSIONAL INTENT THAT EXPORTERS OF DEPLETABLE PRODUCTS BESIDES OIL SHOULD GET FSC BENEFITS.
MAY 4, 1987
PROPOSED REGS CONTRAVENE CONGRESSIONAL INTENT THAT EXPORTERS OF DEPLETABLE PRODUCTS BESIDES OIL SHOULD GET FSC BENEFITS.
DOCUMENT ATTRIBUTES
- AuthorsFalgoust, Dean T.
- Institutional AuthorsFreeport-McMoRan, Inc.
- Code Sections
- Subject Area/Tax Topics
- Index Termsforeign sales corporation (FSC)controlled group of corporations
- Jurisdictions
- LanguageEnglish
- Tax Analysts Document NumberDoc 87-3286
- Tax Analysts Electronic Citation87 TNT 108-16
=============== SUMMARY ===============
Dean T. Falgoust of Freeport-McMoRan, Inc. in New Orleans, La., has commented on the temporary and proposed regulations under section 925 of the Code. Falgoust asserts that regulation section 1.925(a)- 1T(c)(6)(iii)(D) is inconsistent with the intent of the Tax Reform Act of 1984, which specifically made the tax benefits afforded to a foreign sales corporation (FSC) applicable to export sales of depletable mineral products other than oil and gas. According to Falgoust, Congress specifically intended to allow FSC benefits for exporters of depletable products other than oil and gas. He suggests that the regulations provide that "combined taxable income" be determined before any deductions for percentage depletion.
DOCUMENT ATTRIBUTES
- AuthorsFalgoust, Dean T.
- Institutional AuthorsFreeport-McMoRan, Inc.
- Code Sections
- Subject Area/Tax Topics
- Index Termsforeign sales corporation (FSC)controlled group of corporations
- Jurisdictions
- LanguageEnglish
- Tax Analysts Document NumberDoc 87-3286
- Tax Analysts Electronic Citation87 TNT 108-16