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NO CUT AND PASTE PLEASE. SHORT ANSWER. USAco, a domestic corporation, wholly owns a foreign subsidiary in Hong Kong called HKco. USAcosells HKco the seven

NO CUT AND PASTE PLEASE. SHORT ANSWER.

USAco, a domestic corporation, wholly owns a foreign subsidiary in Hong Kong called HKco. USAcosells HKco the seven components necessary to make sunglasses. Following one page of directionswritten in Chinese, HKco employees put the components together to make the sunglasses for HKco'ssale throughout Europe. In order to determine whether USAco has any foreign base company salesincome under Subpart F, the IRS needs to analyze whether HKco's activities constitute manufacturing.What procedures can the IRS employ to gather the information needed to make this determination?

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