Modification of Federal Taxable Income: Internal Revenue Code Subpart F Income

A taxpayer that owns stock in a "Controlled Foreign Corporation," as defined in IRC Section 957, may be required to include in federal taxable income its pro rata share of the subpart F income (as defined in IRC Section 952) of the foreign corporation. If the foreign corporation is included with the taxpayer in a combined report permitted or required under ORS 314.363, any subpart F income attributable to the foreign subsidiary shall be subtracted from federal taxable income in arriving at Oregon taxable income.

NOTE: With the adoption of Oregon Laws 1984, Ch. 1, (Enrolled HB 3029), ORS 317.288 was repealed. This rule will no longer be in effect for taxable years beginning on or after January 1, 1986. For all prior years, this rule shall remain in full force and effect.