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23 VAC Title 23 Agency 10 — Virginia Tax Regulations

23VAC10-120-330

Prohibition of worldwide consolidation or combination

Official textlaw.lis.virginia.gov

A consolidated or combined return may not include a controlled foreign corporation the income of which is derived from sources without the United States.

# 1.

A controlled foreign corporation is a corporation which:

a. is organized under the laws of a foreign country, and

b. has its commercial domicile in a foreign country, and

c. is an affiliate of one or more corporations having income from Virginia sources.

# 2.

The income of a controlled foreign corporation is derived from sources without the United States if:

a. such controlled foreign corporation is not subject to income tax under the laws of the United States, and

b. dividends paid by such controlled foreign corporation would qualify as "income from foreign sources" under § 58.1-302 of the Code of Virginia.

Last amended: Historical Notes Derived from VR630-3-443, eff. January 1, 1985.

Source: view the official text

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Nearby sections (25 sections)
  1. 10-120-280 · Alternative method of allocation and apportionment
  2. 10-120-290 · (Repealed.)
  3. 10-120-300 · Accounting
  4. 10-120-310 · Reports by corporations
  5. 10-120-320 · Consolidated and combined returns; general
  6. 10-120-321 · Separate return; description; filing
  7. 10-120-322 · Consolidated returns; description; eligible members;…
  8. 10-120-323 · Combined returns; description; eligible members; filing;…
  9. 10-120-324 · Consolidated and combined returns; permission to change
  10. 10-120-325 · Consolidated and combined returns; carryovers
  11. 10-120-326 · Consolidated return; mixed apportionment factors
  12. 10-120-327 · Consolidated and combined returns; examples
  13. 10-120-330 · Prohibition of worldwide consolidation or combination
  14. 10-120-340 · (Repealed.)
  15. 10-120-350 · Consolidation of accounts
  16. 10-120-360 · (Repealed.)
  17. 10-120-380 · Execution of returns
  18. 10-120-390 · Supplemental reports
  19. 10-120-400 · Extension of time for filing returns
  20. 10-120-410 · Time of payment of corporation income taxes
  21. 10-120-420 · Declarations of estimated income tax required
  22. 10-120-430 · Time for filing declarations
  23. 10-120-440 · Installment payment of estimated tax
  24. 10-120-450 · (Repealed.)
  25. 10-120-460 · Failure to pay estimated tax
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