35 Miss. Admin. Code Pt. III, Subpt. 8, Ch. 05 — Foreign Sales Corporations (FSC's)

100 Mississippi does not follow Federal Law or Regulations as they relate to Foreign Sales
Corporations except as noted below. For Mississippi purposes an FSC is treated as a
normal corporation. Any sale to an FSC must be at arms -length. Any expense
reimbursement must be reasonable based on the service performed or the expense
incurred by the FSC.
101 Instead of adjusting all transactions to an arms-length basis, the Commissioner may allow
the FSC to consolidate with the parent or other corporation if the result clearly reflects
Mississippi income. This will be decided on a case by case and a year to year basis.
102 Because of the two preceding paragraphs, dividends paid by the FSC to the parent will
not be included in apportionable income of the parent.
103 Mississippi does follow Federal tax treatment in connection with non -recognition of gain
on the transfer of assets from a Domestic International Sales Corporation (DISC) to a
Foreign Sales Corporation (FSC).
104 (Reserved)
105 (Reserved)