Question
USP, a Delaware corporation, owns 100% of each CFC1 (incorporated in the U.K.), CFC2 (incorporated in Germany), and CFC3 (incorporated in the Cayman Islands). CFC3
USP, a Delaware corporation, owns 100% of each CFC1 (incorporated in the U.K.), CFC2 (incorporated in Germany), and CFC3 (incorporated in the Cayman Islands). CFC3 owns 100% of a Mexican entity, HB, which has elected to be a disregarded entity.
Indicate the items (1-6) of income listed below which are items of foreign base company income? (IRC 954(a)) (more than 1 answer)
1.CFC1 buys inventory from USP and sells to customers in the U.K
2.CFC3 buys inventory from USP and sells to customers in Brazil
3.CFC1 buys inventory from USP and sells to CFC2.
4.USP charges for services provided in the UK for CFC1.
5.CFC1 collects income for services of its engineers provided to CFC2 in Germany.
6.CFC1 collects income for services of its engineers provided for contract R&D performed in its U.K. based R&D center.
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