Tax Law Updates | New Statutes, Regulations, and Rulings
May 4, 2010
PricewaterhouseCoopers Issues Comments on IRS Letter Ruling on Foreign Base Company Sales Income
PricewaterhouseCoopers’ Comments on IRS Private Letter Ruling 201002024
PWC on PLR 201002024, 4/6/2010
PricewaterhouseCoopers (“PWC”) has released its comments on Internal Revenue Service (“IRS”) Private Letter Ruling (“PLR”) 201002024 relating to the determination of foreign base company sales income (“FBCSI”).
According to the PWC, the IRS illustrated the application of the tax rate disparity test and other concepts in determining FBCSI under the branch rule of section 954(d)(2). Unlike the prior rulings, PLR 201002024 (released on January 15, 2010) involves branches that are owned by an entity that is treated as a partnership for U.S. federal tax purposes, and appears to address transactions that are governed by prior manufacturing branch regulations, the PWC explained.
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