Treasury Regulations (26 C.F.R.)
26 CFR § 1.927(d)-2T
Temporary regulations; definitions and special rules relating to Foreign Sales Corporation.
# (a) Definition of related supplier.
For purposes of sections 921 through 927 and the regulations under those sections, the term “related supplier” means a related party which directly supplies to a FSC any property or services which the FSC disposes of in a transaction producing foreign trading gross receipts, or a related party which uses the FSC as a commission agent in the disposition of any property or services producing foreign trading gross receipts. A FSC may have different related suppliers with respect to different transactions. If, for example, X owns all the stock of Y, a corporation, and of F, a FSC, and X sells a product to Y which is resold to F, only Y is the related supplier of F. If, however, X sells directly to F and Y also sells directly to F, then, as to the transactions involving direct sales to F, each of X and Y is a related supplier of F.
# (b) Definition of related party.
The term “related party” means a person which is owned or controlled directly or indirectly by the same interests as the FSC within the meaning of section 482 and § 1.482-1(a).
[T.D. 8126, 52 FR 6465, Mar. 3, 1987]
Source: view the official text
In this part (40 sections)
- 1.909-3 · Rules regarding related income and split taxes.
- 1.909-4 · Coordination rules.
- 1.909-5 · 2011 and 2012 splitter arrangements.
- 1.909-6 · Pre-2011 foreign tax credit splitting events.
- 1.910 · [Reserved]
- 1.911-1 · Partial exclusion for earned income from sources within a…
- 1.911-2 · Qualified individuals.
- 1.911-3 · Determination of amount of foreign earned income to be…
- 1.911-4 · Determination of housing cost amount eligible for exclusion…
- 1.911-5 · Special rules for married couples.
- 1.911-6 · Disallowance of deductions, exclusions, and credits.
- 1.911-7 · Procedural rules.
- 1.911-8 · Former deduction for certain expenses of living abroad.
- 1.912-1 · Exclusion of certain cost-of-living allowances.
- 1.912-2 · Exclusion of certain allowances of Foreign Service personnel.
- 1.921-1T · Temporary regulations providing transition rules for DISCs…
- 1.921-2 · Foreign Sales Corporation—general rules.
- 1.927(a)-1T · Temporary regulations; definition of export property.
- 1.927(b)-1T · [Reserved]
- 1.927(d)-1 · [Reserved]
- 1.927(d)-2T · Temporary regulations; definitions and special rules…
- 1.931-1 · Exclusion of certain income from sources within Guam,…
- 1.932-1 · Coordination of United States and Virgin Islands income taxes.
- 1.933-1 · Exclusion of certain income from sources within Puerto Rico.
- 1.934-1 · Limitation on reduction in income tax liability incurred to…
- 1.935-1 · Coordination of individual income taxes with Guam and the…
- 1.936-1 · Elections.
- 1.936-4 · Intangible property income in the absence of an election out.
- 1.936-5 · Intangible property income when an election out is made:…
- 1.936-6 · Intangible property income when an election out is made: Cost…
- 1.936-7 · Manner of making election under section 936 (h)(5); special…
- 1.936-8T · Qualified possession source investment income (temporary).…
- 1.936-9T · Source of qualified possession source investment income…
- 1.936-10 · Qualified investments.
- 1.936-11 · New lines of business prohibited.
- 1.937-1 · Bona fide residency in a possession.
- 1.937-2 · Income from sources within a possession.
- 1.937-3 · Income effectively connected with the conduct of a trade or…
- 1.951-1 · Amounts included in gross income of United States…
- 1.951-2 · [Reserved]